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Missed match for HCE


BG5150

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For some reason, payroll company stopped the matching contribution for everyone mid-2019.

We only do the PS and just enter the match for (a)4 testing.

Owner HCE was maxed out to $62,000.

They are going to make up the match for everyone else.

Should they bother with the owner?  Otherwise, he will have a 415 excess and get some of his deferrals refunded.

(He's the only one with a 415 issue in either 2019 or '20)

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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Depends on the plan document language. I normally see plan language that says that if an allocation/contribution to a participant's account would otherwise causes it to exceed the participant's 415 limit, the allocation/contribution is reduced to not exceed the limit. With language like this, you don't need to make the matching contribution if you know the 415 limit will be exceeded. Bottom line is to look at plan document language.

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