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Mr Bagwell

EPCRS Interpretation

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I'm a little dense today....

I need the following paragraph interpreted for me.  It's safe harbor correction methods for employee elective deferral failures.... page 78. 

For the "No QNEC" needed.

(i ) Correct deferrals begin no later than the earlier of the first payment of compensation made on or after the last day of the three-month period that begins when the failure first occurred for the affected eligible employee or, if the Plan Sponsor was notified of the failure by the affected eligible employee, the first payment of compensation made on or after the end of the month after the month of notification;

Participant notified Employer that contributions weren't right 3/27/2019.  The deferral failure started with the first payroll of 2019, 1/11/2019.  There was an error by the Employer.

There is two pieces to the above paragraph.  The EARLIER.....?

First piece throws me off on really what it means.  Does this mean that if the Employer noticed the error, they have until first payment in April 2019 to get the correct deferrals started?

The second piece I follow, the Employer can get the right percentages coded, send the notice, make sure the appropriate match is made and move on.  The fix needs to be done in April 2019.

It appears that the EARLIER date of correction needs to be implemented by first pay of April 2019. 

Am I interpreting correctly?

 

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You didn't specify but I'm going with the assumption that payroll is biweekly: 1/11, 1/25, 2/1, 2/15, 3/1, 3/15, 3/29, 4/12, 4/26, 5/10, ...

(A) Failure first occurred: 1/11/2019

(B) Last day of the three-month that begins on (A): 4/11/2019

(C) First payment of compensation made on or after (B) 4/12/2019

(D) Plan sponsor notified of the failure by affected eligible employee: 3/27/2019

(E) End of month after the month of (D): 4/30/2019

(F) First payment of compensation made on or after (E): 5/10/2019

Earlier of (C) and (F) : 4/12/2019

Correct deferrals need to begin no later than 4/12/2019.

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