Adding Safe Harbor to Existing 401(k)

[lisabroc]

Is it too late to add safe harbor match provisions to an existing 401(k) plan for 2019?

[Larry Starr]

Any chance you tried googling this before posting? I tried this for ha ha's: adding safe harbor match for next year.

Lots of answers.

Here's just one.  See page 8.

http://product.ftwilliam.com/wp-content/uploads/2017/09/Safe-Harbor-Webinar-2017_FINAL.pdf

The answer, BTW, is no.  It has to be in effect by first day of the plan year.

[Flyboyjohn]

Respectfully disagree with Mr. Starr's flat "No".

If your client is at least moderately aggressive and if the plan can be amended and the 2019 safe harbor notice distributed "quickly" (next couple of days) I would not hesitate going for it.

Remember the IRS position that 30 days advance notice is deemed reasonable doesn't mean that a notice given 20 days in advance is automatically unreasonable.

 

[lisabroc]

Thank you for the PDF link. 

[lisabroc]

Thanks very much, Flyboyjohn. I took Mr. Starr's answer to mean it is not too late:).

[Flyboyjohn]

Agree, I probably misinterpreted his answer, sorry.

[Larry Starr]

On 12/4/2018 at 6:08 PM, Flyboyjohn said:

Respectfully disagree with Mr. Starr's flat "No".

If your client is at least moderately aggressive and if the plan can be amended and the 2019 safe harbor notice distributed "quickly" (next couple of days) I would not hesitate going for it.

Remember the IRS position that 30 days advance notice is deemed reasonable doesn't mean that a notice given 20 days in advance is automatically unreasonable.

 

No you don't!  You agree with me.  Go back and read the question asked, then read my answer of NO.  I said it has to be in effect before 1/1/19, so it CAN be done now.  It is NOT too late!