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SIMPLE IRA excess ER contribution

M Norton

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SIMPLE IRA plan has excess Employer match contributed for 2 participants for 2019 plan year.  The excess match totals $120, but excess is less than $100 for each participant.

Rev Proc 2019-19 says if the excess amount is $100 or less, the Plan Sponsor is not required to distribute the excess..

The question is whether that $100 limit applies by participant or does it apply to the plan as a whole?


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The exception to full correction for overpayments of $100 or less applies on a participant basis. See Rev. Proc. 2019-19, Section 6.01(5)(c).


(c) Recovery of small Overpayments. Generally, if the total amount of an Overpayment to a participant or beneficiary is $100 or less, the Plan Sponsor is not required to seek the return of the Overpayment from the participant or beneficiary. The Plan Sponsor is not required to notify the participant or beneficiary that the Overpayment is not eligible for favorable tax treatment accorded to distributions from the plan (and, specifically, is not eligible for tax-free rollover).


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