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Transfers from a non-ERISA 403(b) to an ERISA plan

Q: Can a non-QCCO (qualified church-controlled organization) transfer assets to an ERISA 403(b) plan from a non-ERISA 403(b) that is a part of a multiple employer plan and is not the lead employer in the MEP but a participating one?

A: I believe that the employer has two choices: (1) terminate the non-ERISA plan and distribute all assets within the required 1-year period; or (2) transfer the assets to the new plan.

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