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Showing content with the highest reputation on 02/21/2017 in all forums

  1. Don't you have a operational failure here for not giving participants the opportunity to make 401k contributions? I certainly think so. I'm assuming the failure was longer than 3 months and as such the QNEC would be 25% of missed deferrals and 100% of the match. Interesting question is, 25% of what? Perhaps 25% of the election the ultimately made? Perhaps 25% of 3% (even though EPCRS is clear that it is based on current year activity). But 25% of zero hardly seems appropriate.
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