Bill 148 Vacation

Location: Ontario We have a vacation purchase/sell program under which employees can opt to buy an additional week of vacation, or sell back an unused week of vacation, each at 2%. The new legislation prescribes that after 5 years of service, vacation entitlement is increased to 3 weeks / 6%. If an employee who has 5+ years of service and is already at 3 weeks vacation, opts to sell back one week of vacation, effectively bringing the employee down to 2 weeks of vacation time (but still meets the statutory minimum of vacation pay), would this be in compliance with the legislation?