Well, in the case of a non-interacting (ideal) Bosonic gas in a 2 dimensional harmonic oscillator you can determine quite easily at which temperature you would have a macroscopic occupation of the ground state. And indeed, this happens for T>0. So, well, this can be viewed as a B.E.C. For the occupation of the ground state you get something like:
[tex]N_0 = \left (1-\left (\frac{T}{T_c}\right )^2\right )N[/tex]
Where [tex]N_0[/tex] is the number of the particles in the ground state, and N the total number of particles.
Don't know what this Mermin-Wagner theorem says about it. To be honest, never even heared of that theorem :)