SSRRS Posted July 17 Posted July 17 I recall a post regarding a DB Plan short plan year, mentioning that if the amendment for the short plan year did not mention anything re prorating or giving an accrual for the short plan year than there are no benefit accruals for the short plan year. 1. Is this correct. Or must the amendment state clearly whether there are or that there are no benfit accruals f93r the short year? 2. If there are no accruals must a 204(h) notice be provided to the participants, as the plan is not frozen? 3. Can one plan amendment include two amendments to For plan or must a separate amendment be drafted for each plan change. Foir example in the amendment that changed the plan year, it will also include a second amendment to the plan that the retirement age will be amended for the following plan year, and that the benfit formula will be changed for the next plan year. Or must these 3 plan changes have a separate amendment drawn up for each change? Seems no problem...but would like to double check. Thank you.
Lou S. Posted July 18 Posted July 18 Check the plan document usually but not always there is language that addresses short plan years and what happens with accruals, if you have an adoption agreement/master text its probably in the master text somewhere. If if is individually designed I'm not sure where it would be. If you are deviating from existing plan terms, address it in the amendment but I don't see why it couldn't be addressed in either a single amendment or a series of amendments. If you are not giving at least a pro-rated accrual credit for the short plan year I'd assume you would want a 204(h) notice addressing the short year and I'd assume you'd have to pass 401(a)(26) on an accrued to date basis. SSRRS and CuseFan 2
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