Group Life & AnnuitiesQuestion 248 of 315

Under ERISA, an employee's own salary-deferral contributions to a 401(k) plan must vest:

a.Over a 3-year cliff schedule
b.Over a 6-year graded schedule
c.After the employee completes 5 years of service
d.Immediately and fully (100%) at the time of contribution

Explanation

ERISA §203 (29 U.S.C. §1053) and IRC §411 require that an employee's own elective salary-deferral contributions to a qualified plan be 100% vested immediately — the employee always owns 100% of what they contributed from their own paycheck. Only EMPLOYER matching or profit-sharing contributions may be subject to a vesting schedule (3-year cliff or 2-to-6-year graded vesting under §411(a)(2)). Option A (3-year cliff) and Option B (6-year graded) describe permissible EMPLOYER-contribution vesting schedules. Option C — 5 years is not a standard schedule under current law (the 5-year cliff was raised to 3-year cliff for matching contributions by PPA 2006). The principle: 'your money vests instantly; your employer's match may take time.'

Law Reference: 29 U.S.C. §1053 (ERISA §203)

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