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The SECURE Act's Eligibility Rules for Long Term, Part-Time Employees: The Good, the Bad, and the Questions
Belfint Lyons Shuman Link to more items from this source
[Guidance Overview]
May 13, 2020

"[C]ounting Eligible Long-Term, Part-Time employees as participants, even if they don't have an account balance in the plan, could cause the plan to become a large plan that requires a financial statement audit.... Can long-term, part-time employees be excluded if they are part of an excluded employee class? ... Can plans with immediate eligibility now exclude from the ADP test long-term, part-time employees who had been participating? ... Once in the test, always in the test?"

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