Belgarath Posted January 8, 2019 Share Posted January 8, 2019 Maybe I'm missing something - can a 403(b) plan allow a certain class of employees to defer, but exclude them from the safe harbor match? I didn't think so... Link to comment Share on other sites More sharing options...
Kevin C Posted January 8, 2019 Share Posted January 8, 2019 You're not missing anything. You can't do that and satisfy the ACP safe harbor. The ACP safe harbor match rules send you to the ADP SH match provisions so each NHCEs eligible to defer has to receive the SH match. You would also have a problem with the match restriction in 1.401(m)-3(d)(4). Link to comment Share on other sites More sharing options...
Pam Shoup Posted January 10, 2019 Share Posted January 10, 2019 What type of entity sponsors the plan? 501(c)3, steeple church, school, etc.? Pamela L. (Bobersky) Shoup CEBS, RPA, QKA AMI Benefit Plan Administrators, Inc. 100 Terra Bella Drive Youngstown, Ohio 44505 800-451-2865 www.amibenefit.com Link to comment Share on other sites More sharing options...
Belgarath Posted January 10, 2019 Author Share Posted January 10, 2019 Thanks Kevin - that's the same answer I had come up with. Ran across a plan that has this, so wondered if I was missing something... Pam, it is a 501(c)(3). Link to comment Share on other sites More sharing options...
MWeddell Posted January 11, 2019 Share Posted January 11, 2019 There is a limited exception to the conclusion reached so far. Those who have not attained age 21 with one year of service can be allowed (and likely must be allowed due to the universal availability rule) to make 403(b) deferrals but can be permissively disaggregated for 401(m) purposes and not allocated the safe harbor match. Link to comment Share on other sites More sharing options...
Belgarath Posted January 11, 2019 Author Share Posted January 11, 2019 Yes, thanks. I had considered that, but it doesn't apply in this plan. I appreciate your taking this extra step. Link to comment Share on other sites More sharing options...
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