401KsRme

Disagreement in our office about when the Cares Act and Secure Act amendments must be done. One person saying 12/31/25 and another saying 12/31/26.

Thank you so much for the reply! These clients come up with crazier scenarios each year - lol

For the 2022 Plan Year, ADP testing was completed and refunds were issued in March 2023. The participants received 1099-R’s in January ’24. It was later discovered the ADP test was run incorrectly, and approx. 10 HCE’s received too much in refunds. A handful of those HCE’s have since terminated employment. This is a large Plan that is audited. How (if at all) can this be corrected? I doubt any of the terminated participants would want to re-deposit the money into the Plan. Would the employer make a QNEC of the amounts refunded in error to those still in the Plan?

Client has a 10% automatic enrollment feature, and the trustee wants to reduce the automatic enrollment rate to 5% and add an automatic escalation feature with 30 day notice now. Can they amend now or do they need to wait until 1/1/26. Plan is a calendar year Plan and no new hires at this time.

Have a client that had their fiscal year end and plan year end 9/30. They changed fiscal year end to 12/31 but didn't change the plans year-end yet. They have a Safe Harbor 3% due for the 9/30/22 plan year end. When does it have to be funded by now that their fiscal year is 12/31?