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I ran the ADP test for my plan, excluding the statutorily excludables. Plan fails the ADP test for 2004. Client decides they want to correct by allocating a QNEC. The QNEC is to be allocated to NHCEs who worked 1000+ hours and were active on the last day of the plan year. As part of the correction report, our system provides the allocation figure. I had the system allocate the QNEC and it provides it to all NHCEs who are eligible for the QNEC, regardless of their status as a non-excludable or excludable. My question is: Isn’t the QNEC supposed to be allocated to ONLY those participants who are non-excludables and in the failed ADP test? Should the excludables receive the QNEC allocation? The plan document does not specify this.

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