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Found 2 results

  1. I have a client that fails the ACP test and is required to refund match to two HCEs. One of the HCE is not fully vested in the match contriubution. How is the refund handled in this case - does he still receive the full refund, or is part of it forfeited?
  2. A plan has a match formula in the Document for which they only make once a year after we do the calculation. At the same time we do the match calculation, we run the ACP test using our calculated numbers. In this case, the ACP test fails using the numbers we projected but were not yet made. Does this need to be done in chronological order (i.e. they make the match and then ACP returns/forfeitures)? Or can any steps be saved in the process and, if so, what? We know that to handle the ACP returns, unvested match amounts get forfeited and vested amounts are distributed. Thank you.
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