How do I apply IRC 411(a)(11)(A) for MEPs

A) IRC 413(c) governs MEPS, and specifically IRC 413(c)(3) determines how vesting rules are determined.

B) IRC 413(c)(3) states that IRC 411 for vesting rules shall apply as if all employers were one employer

C) IRC 411(a)(11)(A) discusses the rules stating that amounts greater than 5000 require spousal consent

 

If a MEP (comprised of many participating employers) has two of those participating employers where a single participant has an account balance in each participating employer's plan. The participant has 2,500 in Employer A's plan and 2501 in Employer B's plan and only Employer A provides for involuntary forceouts. The participant is currently employed at Employer B. If Employer A where the participant has a 2,500 account balance is reviewing this participant in regards to whether to force them out because they are no longer employed at that employer,

 

a) Does the plan administrator consider the 2501 balance in Employer B's plan in determination of whether to force out the 2,500?

 

b) Would the answer to a) change if the participant was no longer employed at employer B?

 

c) Would the answer to a) or b) change if the account balances in both plans were 2500?

 

d) Would the answer to a), b) or c) change if both employers provided for forceouts?