I was thinking of amending a client's plan to a cross-tested allocation for the plan year ending 12/31/08. To make this work, I would need to also amend the NRA from 55 to 65. Since the plan has last day accrual, I don't see an issue with changing the allocation method. Does anyone believe there would be an issue to change the NRA during before the end of the plan year? Thanks.

I don't see a problem with it. Of course you have to grandfather all existing dollars under the 55 NRA, but since you have the last day requirement, 2008 non-elective contributions don't require such protection.

Thanks, Blinky. I would put an in-service distribution at 55 to cover this.

Don't forget vesting.

Thanks again, but not an issue since the plan has full and immediate !