BERPA

Thank you all for your input. I'll suggest allocating as a disc ER contribution and make them aware of the "recycling".

We thought about adding a discretionary match and amending the forfeiture provision to leave use of at the discretion of the employer, effective 1.01.2019. We also thought about using it as a disc ER contribution (integrated at TWB), but don't think it would help because of the turnover.

Plan sponsor (with high employee turnover) eliminated 401(k) plan's fixed matching contribution effective 1.15.2018 and, after payment of expenses, has over $6,000 in forfeiture account. Document provides that match forfeitures be used to reduce match for the plan year in which they occur and to pay expenses. Sponsor will continue to pay expenses from the account, but it may take a few years. Does anyone think there would be an issue? It's not like the account accumulated over a period of several years and we're following the terms of the plan. Not sure what else we can do.