Is this a partial termination

Hi

CB plan with 0/0/100 vesting. This is the second year. (Plan year is 7/1/2020 to 6/30/2021)

Currently 5 eligible employees, 1 owner, 1 non-owner HCE and 3 non-HCE

2 non-HCEs are leaving (or fired - do not know yet).

The only new hire is is from beginning of plan year and he is the spouse of the owner.

Does not look like additional new employees to be hired for the next 6 to 12 months.

Do I have a partial termination issue? Does it matter if the employees are terminating before or after 1000 hour accrual?

Thank you

Seems to me you need to find out the REASON those 2 NHCEs are leaving.  The crux of determining a partial plan termination is whether the terminations are employer-initiated.  Based on the math you've provided, if these 2 NHCEs were fired, you have a PPT on your hands.  In that case, the hours they've worked are not a factor as they become 100% vested regardless.  All PPT determinations are facts & circumstances, so it may be advisable to get a legal opinion.

Thank you for your comments