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Showing results for tags '415 excess'.
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415 excess 415 Excess - Past Deadline - True Ups also due...
401kology posted a topic in 401(k) Plans
Assisting a sponsor that discovered that the 415 limits were tested before the final true up. The participants are due additional safe harbor match, that will cause more excess that needs to be distributed. Participants that are affected should have had after-tax refunded but have since rolled over account balances to new employers plans. Would depositing the true up and processing the excess from the additional allocation be permitted since that is all that remains in the plan? The only other solution is to issue the letter that they have to take the excess out of the current plan and then let them know they have additional that can be rolled over, which does not sound correct. Anyone run into this situation? The 415 excess must be corrected, but the regs only address the order not necessarily what to do if the other sources have been distributed. -
Hi all, I have a 401k plan where participant terminated employment in early 2018 and received a taxable distribution in 2018. His pre tax deferral, Roth contribution and match exceeded his compensation for the year resulting in 415 issue. In looking at EPCRS per our VS in 415 excess situation, it seems the correction is to distribute the funds plus earnings to him. We already did this. Client wants to self correct since the total excess is under $100. Am I missing something, Is there anything we need to do other than document? Thanks for any help!
