SIMPLE deferrals not taken from bonus

[Guest bmurphy]

Employer just realized that they have not taken deferrals from one-time bonus paid earlier this year & over last few years. They will rectify going forward - are they required to make corrections for prior occurences? Employer would rather not unless regs require it. If they are required, what is correct procedure?

[Gary Lesser]

Under the EPCRS, the employer should make the required contributions (and any matches). Unless actual ernings known, a reasonable interest rate may be used. See Rev Proc 2003-44, App A (Sec .05)--Exclusion of an eligible employee.....