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Interesting question which I addressed in this article. http://www.healthcare-attorneys.com/dont-accept-accepted-with-errors-how-to-handle-incorrect-tins/ I also touch on the issue in this article http://www.healthcare-attorneys.com/corrected-returns-when-an-employer-needs-to-file-a-corrected-form-1095-c/ I agree it is not entirely clear what the responsibilities are for an employer who receives an accepted with errors response for an incorrect TIN. Ryan

With respect to your Point "4" above: "Past performance is not a guarantee of future performance." Retirement plan investing is LONG TERM, and the past 2 years are but a blip in the time horizon. Plus, when the market is low, you are "dollar cost averaging" into cheaper shares/units which, when the market rebounds will magnify the upside.

this is no different, perhaps, than a person's last paycheck. let's say the person quits Dec 27, 2015 and his final paycheck is in January. he deferred so do you show the deferral in 2015 or 2016? for tax purposes we know the W-2 shows the deferrals in 2016 and most would show the deferrals on the 2016 ADP test as well unless the document specifically uses the 'paycheck received in the last few weeks'

If they use compensation from the date eligible in testing, that will include the 7/5 payroll. For that reason, I always encourage my clients to use the first payroll after the entry date to start contributions.