Another LTPT Question - (sorry)

I saw an article in the Newsletter the other day regarding LTPT.  The article said (paraphrasing), that in general the IRS has said that all years of service must be taken into account when determining vesting for an LTPT.  

Wasn't it SECURE 2.0 or some other more recent guidance that allowed 401(k) plans to not count years prior to January 1, 2021 for vesting?

Thanks.

An individual who is eligible to participate in the plan "solely by reason of being LTPT employee" will be the lucky winner of the 500 hour requirement for vesting purposes.  Since LTPT employees aren't recognized prior to 2021, I don't see that service prior to 2021 would apply.

I am, of course, using logic here.  One never knows whether logic applies with our regulatory agencies . . . 

Gilmore, your recollection is correct.  Section 112(b) of the original SECURE Act states that only eligibility computation periods beginning on or after January 1, 2021, are taken into account in determining part-time employees' eligibility.

Unfortunately, the LTPT vesting service rules have no such restriction.

Does Section 125 (d) of SECURE 2.0 limit years counted for vesting to those after 12/31/2020?  I see that section has a lot of strike this, and insert this, but everything that I'm finding that says years prior to 2021 are not counted for vesting reference 125(d).

The section by section legislative summary of SECURE 2.0 says "Section 125 also provides that pre-2021 service is disregarded for vesting purposes..."

https://www.finance.senate.gov/imo/media/doc/Secure 2.0_Section by Section Summary 12-19-22 FINAL.pdf