Melissa2115

Thank you for responding and confirming what we believed.

Can I add more questions to this message, please? Failed ADP test with refunds, all completed prior to March 15th. Non-HCE just "learns" that he maxed his deferrals under his prior employer's plan during 2021. The $14k he deferred to this plan is now a 402g excess. Are his deferrals eliminated from the ADP test thereby causing more failure = greater refunds? We believe the reg quoted above alludes to how you handle the excess deferral in the same plan. But how do we treat the excess deferral in this situation when another employer is involved? This plan will issue the 402g refund, fyi. TIA

Thank you! We are going with the interpretation that because you are allowed to disregard a contribution receivable, you are permitted to change the calculation method from one year to the next.

For a trustee-directed plan, we have historically calculated the RMDs once we've accrued the contribution. The participants ending balance at 12/31/2021 would be equal to the actual investment balance plus their contribution receivable. The participant wants his RMD in January before we know the accrued contribution amount. Can we modify our methodology and calculate the RMD based on just the value of the investments going forward? We don't have the accrued contribution amount available in January. Thank you!