A sponsor deconverted from a MEP (9/1/19) and started a new 401k plan (10/1/19). Generally, we write our plan documents for mid year starter plans to have a Jan 1 effective date and then note effective dates for each plan feature such as Safe Harbor, deferrals that reflect when the plan actually started. We have all calendar year plans and define our compensation as the plan year, writing our docs with those dates allows the sponsor to provide just the one set of compensation (for full 12 months) instead of partial year compensation and statutory.
Can we date the doc for this plan like that? If the effective date of the plan is when they were actually with the MEP is that a problem?
