What is the right basis for correcting an MDO for automatic enrollment? 50% of the ADP, or the pct of the auto enrollment?
Here it looks like it would be 50% of the auto enrollment pct:
https://www.irs.gov/retirement-plans/fixing-common-plan-mistakes-correcting-a-failure-to-effect-employee-deferral-elections
Our situation: elections are made on our recordkeeper site, and transfer over to our payroll system. Due to human error, some elections were not transferred. These non-transferred errors include automatic enrollments as well as positive elections.
It seems to me that all these participants were given the option to defer, as they received info from the recordkeeper and were directed to the site. As they were given the opportunity, this 401k plan fix would not apply:
https://www.irs.gov/retirement-plans/401k-plan-fix-it-guide-eligible-employees-were-not-given-the-opportunity-to-make-an-elective-deferral-election-excluding-eligible-employees
Thanks in advance for any comments!
