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Found 2 results

  1. John Feldt ERPA CPC QPA
    New safe harbor plan was executed timely to begin deferrals and safe harbor on October 1, 2015, plan is a December 31 year-end. They failed to offer deferrals until sometime in November. Under Revenue Procedure 2015-28, if the problem is found and deferrals start in the 3 month period, no QNEC is needed for the missed deferrals assuming the proper notice is provided? Seems like that's the case since an Employee Elective Deferral Failure includes a failure to afford an employee the opportunity to make an election. Agree?
  2. Zorro1k
    Does anyone know if under Rev. Proc. 2015-28 a correction can be made if the failure comes from a failure to auto-enroll when implementing a new auto-enrollment feature versus failing to enroll a participant in an existing auto-enroll plan? If I implement the feature and miss participants, are the reduced correction fees available?
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