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Recharacterizing matching contributions as catch-up contributions to correct ACP failure

Guest cpp

By Guest cpp
in Correction of Plan Defects

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Guest cpp

Guest cpp

Posted
Posted

If a plan with matching contributions fails the ACP test, can a plan sponsor recharacterize the excess matching contributions as catch-up contributions for participants over age 50?

MGB

MGB

Posted
Posted

No.

Catch up contributions MUST be elective deferrals. It cannot come from the employer.

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