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legort69

Excess Deferral unrelated plans and ADP Refund

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Hope everyone is practicing safe social distancing.

We have a participant who makes contributions to 2 plans. We administer one of the plans.

He is an HCE and receives an ADP refund in the plan that we administer.

Later he provides proof of combined excess deferrals between both plans.

My question is whether the 402g excess deferral refund is a refund in addition to the ADP refund, or can the 402g excess be included as part of the ADP refund?

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