One-to-One QNEC question.

[fiona1]

So if you fail an ADP or ACP test, you have 12 months to make a correction. If you don't make a correction within the 12 month prescribed correction period - then you have an operational failure on your hand.

You can use the Self Correction Program in the EPCRS - and one of the options is the One-to-One Correction Method, which involves the refunds being made and a QNEC in the same amount allocated to the NHCE's.

If a plan allows for forfeitures to offset employer contributions, can they use the forfeitures to fund the QNEC? Or, is this considered a corrective QNEC and would forfeitures not be allowed to fund this?

Thanks for any insight.

[Tom Poje]

I think example 2 in appendix B of the EPCRS implies you can use the forfeitures (according to document terms). the one stipulation is that forfeitures are used as described in the document in the year of failure - just in case anamendment has changed things.

[fiona1]

Thanks Tom.