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MarZDoates

Late deposit of SIMPLE IRA deferrals - exclusive plan rule

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Plan sponsor terminated their SIMPLE IRA plan 12/31/18.  They started a new 401(k) effective 1/1/19.  Employer just now realizing they missed depositing SIMPLE deductions/deferrals for payrolls occurring in December, 2018.  

Will it violate the exclusive plan rule to deposit the SIMPLE deferrals now (in 2019) along with lost earnings?  I'm thinking "no" because we are correcting late deposit of deferrals for 2018.

I'm probably overthinking as usual.

Any input greatly appreciated!!

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