ACP earnings

[Guest Phil Schwartz]

If the match is deposited after the close of the year, is it reasonable for earnings for a failed ACP test to be 0? (pre-final regs)

[WDIK]

What is the methodology described in the plan for allocating gains or losses to a participant's account? (and what options does the document give for determining the allocable income for the returns?)

[Guest Phil Schwartz]

It's a daily valuation plan

[WDIK]

It appears that the approach you are proposing as a reasonable allocation method is consistent with the method that is used by the plan for allocating income to participant's accounts.

You should also determine if the allocation method is being used consistentely across all participants and all corrective distributions. Does the metholdogy you are using for earnings on ADP returns take into account the deposit date of the deferrals? Or to put it another way, are you using the same formula in both the ADP and ACP scenario and coming up with zero earnings on the returned matching contributions?