402g Limit - plan had changes during the year

[Guest Achilles]

I have a plan (12/31 pye) that during 2002, for the 1st qtr. they had a deferral limit of 20%.

Effective 4/1/02, they changed the limit to the 402g limit of $11,000.00.

How could I determine the annual limit for 2002?

They had a percent for 1/4 of the year, and a dollar amount for 3/4 of the year.

If they had 2 separate percents, with a change mid-year, it would be easy, just average the 2.

Thanks in advance!

[Blinky the 3-eyed Fish]

What 2002 annual limit are you trying to determine? I don't follow.

[Guest Achilles]

The annual deferral limit - 402g limit was $11,000 in 2002.

This plan had 2 separate limits in 2002 for their deferrals - 20% of comp. for the 1st quarter, then switched to just the $11,000 limit for the 2nd, 3rd & 4th qtr's.

I have to re-classify some catch-up cont's back to deferrals, because some participants did not reach the required limit, yet they still made a catch-up cont.

I need to find one limit for the year.

[E as in ERISA]

So you're trying to decide which contributions are catchups? Wouldn't it just be the excess over $11,000?

The plan allows someone to contribute the full $11,000 during the last three quarters, doesn't it? The regs require you to apply the plan limit on a plan year basis. When you have two different plan limits during a year, you are supposed to use the sum of the two limits. So that would be .20x + $11,000 (with x being 1st quarter compensation). But the 402(g) limit will always limit you to $11,000, won't it?