Bri

If the 401(k) election is recorded in writing to authorize the 24,000, then you simply have a late 401k deposit issue.

They ought to be able to, but they might need to convince either sponsor the excess has really occurred. (Otherwise this is a request for a random-ish looking withdrawal absent the knowledge of the other plan.)

415 limit is 100% of pay, not to be confused with the 25% 404 limit. None of this needs to be "employer" money. Every dollar of "profit sharing" reduces his Earned Income by the same dollar he could have done more deferral from.

True, you end up with the same max whether it's PS + K versus all being K, but you don't have any catchups since he's below the 402(g) max.

That doesn't sound so weird - but what if the exclusion was only part of the year? Would you use full year amounts or only those where the guy wasn't in an overlooked status? As a parallel to the original scenario, people who aren't eligible for a 401(k) plan at all because of their division or job category wouldn't show up as zeros in the ADP test. This is sort of inadvertently similar.

Doesn't sound like a severance of employment to me.....

I'd be treating this as a short-term impermissible loan and expect the appropriate interest returned to the plan as well to fully correct it as a prohibited transaction.

That's a more recent version, but yup!

Did you pair the proper Relius account number to that source? Like, maybe your account 201 is accidentally the match source.

Only match money can be used to refund a match test failure, definitely don't swap sources. But hey, just count the amounts to refund out of his prior distribution.

Happy retirement! I know I have a printoff of yours at least 20 years and four jobs ago detailing which Code sections don't apply to government plans, it's been a fantastic resource to have!

They should pop up if you slowly type the start of a user's name here in the comment space. @fmsinc Yours came up first on the list after I typed the @ and the f - I was given a pop-up menu of several BL users to choose from.

I bet their recordkeeping software could do it within a minute.

So if he's got the derived Earned Income number popping in somewhere else, that becomes the B2 in Miles's formula above.

No, QNECs are not subject to 402(g). Somebody could do 24,500 AND get a QNEC. They're nonelective contributions, so I suppose a sponsor could give someone a 72,000 QNEC if they wanted to be that *one* employer..... They are included in the 401(k) test if the employer elects to treat them that way. So in theory, not necessarily, but it's one of those things where the sponsor's probably making them only with the intent of including them. (And then the 401a4 rules can get slightly annoying if you do have QNECs being used in the ADP test.)

As long as they're permitted by your plan document, then that's absolutely a workable solution to the test results. QNECs in and of themselves can exist for no particular reason other than Sponsor goodwill. But they're usually provided specifically because of how they help testing results.

Well, the 31% limit is going to be 117,800. The DC portion of that can't go over 95,000. If there is a mandatory DB amount that's nonzero, that eats into the 117,800.

I suppose it depends on whether or not the DB contribution is mandatory or not. If their MRC is 0 then they could skip DB funding and do the 25% DC.

Isn't this the technicality on the difference between Nx and N(12)x?

I'd be using Excel's "text to columns" feature to be able to generate a CSV file from the original TXT, but that's because I prefer delimiters to fixed-width.

Yeah, I'm not sure you need to separate the funds, since you should be separating the recordkeeping behind the scenes. The gains on the Roth are computed the same way as they are on pre-tax accounts in a pooled setting.

Either of those sound pretty good.

You're spot on, actually. Failure to follow the plan document, for starters....

Sure, if there are no CB accruals then your gateway drops back to whatever your DC allocation itself will require, including potential TH.

Indeed, no sense creating a MDO for everyone else to fix one mistake.