We are considering the freeze/partial freeze/eliminate question for our Defined Benefit plan.  We are trying to consider all issues while making this decision.  One issue that was brought to my attention by another HR professional is that there might be a MINIMUM NUMBER of participants required by ERISA in order to maintain a DB plan.  In other words, should we decide to only partially freeze the plan (and leave the plan in place for a grandfathered group of people with no new entries, and no new accruals), at what point would be be forced to totally eliminate the plan due to not meeting the minimum number of participants in that plan?

Lisa:

I don’t believe that there is a general ERISA requirement that a plan have a certain minimum number of participants (that is, you can have a one-person plan).  That said, there might be special rules for plan freezes.  Here are a few articles that might help:

Defined Benefit Plan Freezes: Who’s Affected, How Much, and Replacing Lost Accurals.

When plans freeze, HR duties don’t: after freezing a defined benefit pension plan, HR still must meet plan participant…