Seperate vesting on each year's PS contrib?

We have a company that would like to have each year's PS contribution to be on a separate vesting schedule.  It would be a 4-yr cliff.  Assume no Top Heavy.

So, it would look something like this:

2019 contrib fully vests 2023

2020 contrib fully vests 2024

2021 contrib fully vests 2025, etc.

I don't think this is possible due to the minimum vesting standards.  For example, someone hired in 2019 has 4 years service in 2023, so the 2020 contribution would have to be 100% vested for that person in 2023, not 2024.

Is there any way around it?

Class year vesting was eliminated a long time ago - there was a discussion on that here within the last month or so.

The only way to do that would be to adopt a brand new plan every year and exclude service before the plan's effective date, but 4-year cliff still wouldn't be permitted, and I'm sure IRS would have big issues with this when they caught up with you anyway.

A possible, but complicated, way around it was discussed in the prior string which CuseFan mentioned.  It might work for NHCEs and/or very modest contemplated per-person contributions, but other than that I would stay away from it.  

we had one union plan (thank heavens no more) that had a limited modified cliff vesting, but that is as close to cliff vesting as I have seen. of course the software couldn't handle it...

4 hours ago, BG5150 said:

We have a company that would like to have each year's PS contribution to be on a separate vesting schedule.  It would be a 4-yr cliff.  Assume no Top Heavy.

So, it would look something like this:

2019 contrib fully vests 2023

2020 contrib fully vests 2024

2021 contrib fully vests 2025, etc.

I don't think this is possible due to the minimum vesting standards.  For example, someone hired in 2019 has 4 years service in 2023, so the 2020 contribution would have to be 100% vested for that person in 2023, not 2024.

Is there any way around it?

I tell my employees all the time: it's ok to tell clients NO when that is the answer.  In this case, that is the answer.  Usually, they just say "oh, ok".

thanks, all