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  1. Plan provides immediate eligibility for CODA and 12 month/21 statutory eligibility for SH match. Employee met the 12 months and entered the plan on 10/1 (calendar year plan). Plan does SH match per pay period. SH regs say that the SH much be made for all comp during the period in which an employee is eligible defer, which was all year. So does the employer have to go back and deposit the SH match for the first 9 months of the year prior to the employee being eligible for the SH match? Does your answer change if the plan does a true up of the match at year end?
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