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Yes and yes. The catch-up limit is applied using the participant's taxable year. 1.414(v)-1(c)(1). The date the deferrals become catch-up is determined using the timing rules in 1.414(v)-1(c)(3). The timing tells you which plan year includes the catch-ups, which don't count towards the 415 limit.

Y2K issues - Yet another thing that was not included on my 2020 BINGO card...

Assuming this is the first plan that the sponsor has had, then the 5500 is correct and the plan isn't. I would make the change to 001 in writing with a brief explanation of the typographical error and move on. Interesting that the CPA firm never mentioned it before. Or the firm that did the last restatement. WCP

A balanced fund. There is a temptation to think that a generic, old-fashioned balanced fund that does not take age into must violate fiduciary duty, and maybe someone will claim that, and even claim that successfully (some courts will do anything), but how can that be? Before the 404(c) regs in the late 80's, many plans had just one fund, and ERISA really assumes there will be one fund, with 404(c) being the exception that has swallowed the rule. Amending a plan to make it self-directed is at least traditionally viewed as a settlor function, not fiduciary, although if someone wanted to pay me to do it I might try to argue that given the easy of implementing self-direction in today's market, and its obvious advantages for a diverse labor force, the decision not to be a 404(c) plan was fiduciary.

Thanks.