We have quite a few profit sharing plans that have 3/20 vesting and were wondering if the plans had to be amended currently to reflect the 2/20 minimum vesting requirement under PPA, or could that change just be made part of the PPA restatement that will happen a couple of years from now as long as the plan operationally uses the 2/20 schedule from now on? All help is appreciated.

I'm sure amendments will need to be adopted before 12/31/07. Are you using Corbel documents? If so, I'm sure they will be forthcoming. Really any document provider should have them eventually. They're probably waiting for some more guidance to materialize. I think starting with EGTRRA (i.e., post GUST) they abandoned the "wait till the next big restatement" philosophy, but you never know...

The Pension Protection Act requires the plan to be amended by 2009, I believe, but must be operated under the new vesting requirements for contributions made for plan years which begin after December 31, 2006. Some providers have amendments available so you can amend now and not worry about.

Whether you amend now or wait until 2009 to amend, you must apply the new vesting requirements effective January 1, 2007.