ERISAAPPLE Posted December 13, 2017 Posted December 13, 2017 We have an individually-designed safe harbor plan that has 100% vesting for all accounts, including the profit sharing and discretionary match. Is the plan required to adopt an interim amendment to provide that QNECs/QMACs will be vested when allocated? I can't imagine they would.
ETA Consulting LLC Posted December 13, 2017 Posted December 13, 2017 I don't think it would be "required", but necessary if you were to ever use forfeitures to offset these contributions. Good Luck! CPC, QPA, QKA, TGPC, ERPA
RatherBeGolfing Posted December 13, 2017 Posted December 13, 2017 Nope, there is no requirement to have that language in your plan. For an IDP with 100% vesting for all contributions, I wouldn't bother with the amendment. If the plan is amended in the future to include contributions that are not 100% vested, just add the forfeiture language at that point.
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