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ADP Test - Potential Catch-up Contributions in Multiple Plans


PensionPro
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The simplified facts are ... A catch-up eligible individual participated in a CY 401(k) plan through September 30, 2020 and deferred $19,500.  A portion of the plan gets spun off and the individual defers $6,500 in the new plan in  Q4.  

Can I use $6,500 as catch up in the first plan and not use any catch-up in the second plan?  i.e. treat the individual as deferring $13,000 plus $6,500 catch-up in the first plan, and $6,500 and zero catch-up in the second plan.  It seems that should be fine, but I want to check if I am missing something.  Thank you!

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1 hour ago, Lou S. said:

Are the plans related employers or unrelated?

It is the same employer who was participating in one MEP for part of the year, then in a different MEP for the rest of the year.  The employee received one W-2 from the employer showing deferrals of $26,000.  We are in a position to determine testing in both plans.

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On 7/21/2021 at 10:26 AM, Lou S. said:

If it's the same employer isn't there only one test for the full year?

One test for two different plans covering different periods?  I am not sure about that but could you explain why you think there should be one test.  I am trying to figure this out and I appreciate any help in thinking this through.

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Is the employer running 2 tests for 2 short plan years? one for PYE 1/1 - 9/30 and one for PYE 10/1 - 12/31?

Either way the particiant is going to have 1 catch-up for the calendar year.

So if you fail the 9/30 test and recharaterize say the full $6,500 catch-up on the 9-30 plan year then you would include all of the $6,500 deferred in the 4th quarter in that test.

If you pass for 9/30 and don't recharaterize, then all of the 4th quarter is catch-up since it is now over the 402(g) limit and not in your test.

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My question really was am I forced to consider all catch up in the second plan because sequentially the contributions to the second plan are over the 402g limit.  Participant deferred 19.5k in first plan hits 402g limit, then makes 6.5k "catch-up" in the second plan.  I am inclined to say no, and use ADP catch-up in the first plan.  Thanks for your help.

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I don't understand why this question is being asked.  A catch-up either exists or doesn't.  As stated above, if there are catch-ups in the plan that ends 9/30 then there are fewer if not zero catch-ups in the subsequent stub period.

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I would do a single test for the entire year.  I don't think moving from MEP to MEP requires you to run separate tests.  Even if there is some justification for running multiple tests (I'd love some examples where people think this is appropriate), I think you could rely on permissive aggregation.

 

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