Lauren0507

EPCRS provides the missed deferral opportunity (MDO) is equal to 50% of the employee's missed deferral. The missed deferral is determined by multiplying the ADP of the employee's group (HCE/NHCE) by the employee's compensation. We have a situation in which 2 HCEs participated in the plan 2014-2018 and during each of those years a NHCE was not given the opportunity to defer. Since there is no NHCE group in the Plan, how is the missed deferral determined?

Thanks so much for the responses. Happy New Year!

A defined contribution plan currently provides that death benefits must be paid out over 5 years generally, but allows for extended payments to a participant's spouse. The client wants to remove extended payments and apply the 5 year rule to all beneficiaries, including the spouse. The plan does not allow annuity distributions. Are the extended payments protected or may they be eliminated as an optional form of benefit?