Authorization to Withhold Catch-up

[Gruegen]

My understanding of the catch-up regulations is that a participant does not have to make any type of affirmative election to make or designate amounts as catch-up contributions.

However, assuming that a plan document states that an employee may enter into a salary reduction agreement to withhold amounts from their paycheck only up to the 402(g) limit, does the participant have to give their employer an affirmative election to withhold catch-up amounts which are beyond the 402(g) limit??

I guess I see three options:

1) Amend the plan document to provide for a maximum salary reductions equal to the sum of 402(g) + 414(v).

2) Make the participant complete an additional salary reduction agreement for catch-up contributions.

3) Amend the participant's salary reduction agreement form so that the participant authorizes salary reductions beyond the 402(g) limit.

Anyone see any other options. Just curious how other shops are handling this issue.

[four01kman]

All the admin forms I've seen have a check box on the enrollment / change of contribution form to provide for those employee/participants contributing at the maximum, they may make a "catch-up" provided they are age 50 or older in that year.