KimS

S and D both acknowledge that P is the father of both children, but D's birth certificate does not name the father. FWIW when I was adopted in Kansas in 1970, my original birth certificate was sealed and a new one issued.

We're a small TPA firm. I've run into multiple ERISA attorneys advising our mutual clients lately that they must do a 50% QNEC for missed deferrals in situations that seem to me to clearly fall under Rev. Proc. 2015-28 for a reduced QNEC. The first one said that the lower QNEC can only be used if it is a failure to enroll -- not a failure to follow an election for an existing participant. In this case it was a failure to withhold from bonuses. It was caught and corrected almost immediately. The second one was a new plan that failed to implement auto enrollment for anyone for several months after the plan began. This is clearly the exact scenario described in the Rev Proc. I won't know until a call tomorrow why the attorney believes it doesn't apply. Are others finding similar resistance to proposed correction methods?