True Up Matching Contributions

[J. Bringhurst]

Can anyone tell me whether true-up matching contributions (under a plan that provides for matching contributions on a payroll by payroll basis) that have a last day of the year requirement have to be tested as a benefit, right or feature (i.e., different rate of match)?

[Leopurrd]

i would think that if the plan calls for match on a payroll basis you would not true up.

However, if the plan calls for match based on the plan year, and the company has put in the match by payroll (which would generally require a true up) you would not test BRF, only 410b on the contribs in general.

Basically, just follow how your doc requires you to calc the match and you should be fine.

[J. Bringhurst]

Thank you!

[Bird]

Can anyone tell me whether true-up matching contributions (under a plan that provides for matching contributions on a payroll by payroll basis) that have a last day of the year requirement have to be tested as a benefit, right or feature (i.e., different rate of match)?

So the intent is to match each payroll while employed, and just make a true-up for those still employed at the end of the year? Maybe I'm sheltered, but I'd have to think that calls for some convoluted plan language. I don't see the point but oh well.

I agree that you just test the contributions.

[J. Bringhurst]

At this point, it's more of an academic question...whether the last day of the year requirement on a true up constitutes a different rate of match...and needs BRF testing.