Entry Dates - different for sources

We have a takeover client that has 90-day wait for deferrals and 1 year wait for non-safe harbor match and PS with entry on the first day of the plan year.  That is fine.  But they want to change to a 1 year of service for deferrals too.  I will tell them they have to change to semi-annual entry dates for deferrals.  I want to tell them semi-annual for all contributions which is very standard with our clients.  I suppose they could still have only one entry date, first day of plan year, for match and PS only since they could require 2 years to enter for those sources, right?  I will strongly recommend against one entry date since I believe they or their payroll company will mess up the pay-period match.

Comments are appreciated. Tom

51 minutes ago, Tom said:

1 year wait for non-safe harbor match and PS with entry on the first day of the plan year.

As you mentioned, this is ok under the 2-year eligibility rule, because someone who was hired on 1/3/2023 would complete 1 year on 1/3/2024 and then enter the plan on 1/1/2025. This requires that the match and PS both have 100% immediate vesting.

For deferrals, the plan could have a single entry date, as long as the application of that entry date with the associated service requirement does not result in any participant entering the plan later than either the first day of the plan year or 6 months following the date they complete a year of service. For example, the plan could impose a 6-month service requirement with entry on the first day of the plan year only. The participant hired on 1/3/2023 would enter on 1/1/2024 (six months earlier than they would with semi-annual entry dates), but a participant hired on 12/29/2023 would enter on 1/1/2025, the same as if the plan had semi-annual entry dates.