Exclusion of eligible employees

[Guest philc]

Plan excluded a few eligible employees from making deferrals and receiving a Match. Under RP 2003-44 the suggested correction method is to make a QNEC for the missed deferrals and the related Match.

If the intent is to put the Plan where it would have been had no error occurred, rather than make a QNEC for the Match, are you suggesting an alternative would be to make the missed employer Match but put it into the "regular Match" source and subject it to vesting and the other plan provisions applicable to the Matching contributions?

If you do, are you suggesting VCP for this method or just applying SCP criteria?

[actuarysmith]

This problem could be self-corrected. SCP