Pre-ERISA vesting rules

With few notable exceptions, the statutory and regulatory references we need in the administration of plans are at our fingertips from a number of easily accessible internet resources, a great deal of them actually available for free. One of the most annoying of those “notable exceptions” is found under Code Section 411(e) (6) of the Code, the vesting standards which apply to governmental and church 401(a) plans. Section 411(e)(2) states, in pertinent part, that these plans “shall be treated as meeting the requirements of this section, for purposes of section 401(a), if such plan meets the vesting requirements resulting from the application of sections 401(a)(4) and 401(a)(7) as in effect on September 1, 1974.” You can find those here.


Continue Reading The Hard-To-Find “Pre-ERISA Vesting Rules” for Church and Governmental Plans