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Gilmore created a topic in 401(k) Plans
"[A recent] article said (paraphrasing), that in general the IRS has said that all years of service must be taken into account when determining vesting for an LTPT. Wasn't it SECURE 2.0 or some other more recent guidance that allowed 401(k) plans to not count years prior to January 1, 2021 for vesting?"
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TPApril created a topic in Form 5500
"New Plan: - Adopted 5/1/22
- Effective 1/1/22
- 401(k) and Match only as of 7/1/22
- No Employer Contributions which are allocated based on the 1/1/22 date
- Participants with Balance Count at 12/31/22: 150
I believe that they do not qualify for any of the exceptions to filing as a large plan with a set of audited financial statements, but curious of other thoughts.
- Short plan year exception - although the plan only had contributions moving forward during part of the plan year, the plan was declared effective as of 1/1, so no exception here
- Over 120 - There were more than 120 participants at eoy, so no exception.".
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Lois Baker, J.D., President
David Rhett Baker, J.D., Editor and Publisher
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