Bill D.

I have a plan that has four participants that maxed out pre-tax deferrals, all of them also made after-tax (non-roth) deferrals, and all received some safe harbor match during the year. Based on contributions made each pay period, they all reached their 415 limit as of the last paydate. However, the plan requires that a safe harbor match true-up be done. Each of the four is due to receive a true-up, but that true-up will push them over the 415 limit. Since it's a match and required by the document I'm leaning to allowing it to go through then just deal with the 415 excess and refund accordingly. However, another person here believes that, since we know this true-up will push them over the 415 limit we should not allow it to go through, so that means they won't receive the match they are required to. Thoughts? I've struggled to find clarification if we should allow this true-up to go through, deal with 415 refunds, or just not provide the true-up and 415 passes.

Brain freeze here: Plan has dual elig. & entry, 3 months svc. & quarterly entry for deferrals, and 1 year, semi-annual entry for safe harbor match, safe harbor added in 2019. Two scenarios need help on: Former participant termed 2018, rehired 8/1/2020, was a participant for several years prior to 2018 termination. Is this person eligible to defer and receive safe harbor immediately starting on rehire of 8/1/2020? Similar scenario, but this EE has been working for several years, was eligible in past, but never wanted to defer, he now wants to. Can he start deferring now in paydate 9/25/2020, and also receive the safe harbor for 9/25, or, would he have to wait till 1st paydate after 10/1 deferral entry and would he have to wait till 1/1/2021 to start receiving safe harbor? Thanks in advance.