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Posted

Im not sure what the question is here. What employees/participants are you questioning?

How many participants were eligible on the first day of the first plan year (5a)?

For the first year, I would expect 5d(1) to equal 5(a) since you probably don't have any former employees who are participants on the first day of the first plan year.  

 

 

Posted

I am not sure what the question is also.   Read the plan document.   Does the plan allow anyone to enter the plan as of the first day the plan is effective?  If so, you need something besides 0 there in most cases.  

You can make a case if the plan was signed on 12/30/2020 and effective back to 1/1/2020 that no one was a participant on 1/1/2020 (thinking of a PSP not 401(k) in this example where you make it effective back to 1/1 to use full year compensation).   I have seen people make that case but it tends to only come  up if it makes a difference if the plan needs an audit or not.  It looks like your numbers are so low that doesn't matter.  

So go with the first part of this.  What does the plan document say?   Did someone enter the plan as of the first day of the plan?  

Posted

yeah - it's that simple - was anyone a participant as of the first day of the plan year (i.e. what is the plan entry date)?  If they were then assuming they didn't terminate on that day they would also be an "active" participant.

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