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Failed ADP Test and Matching on Catch-ups


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Guest Golden401k
Posted

I have a plan document that doesn't match on catch-up contributions. Don't ask why. If I fail the ADP test and reclassify my refunds as catch-ups, do I have to take away the match that was applied on these catch-ups prior to the test? My guess is YES. Please confirm.

Posted

I would say yes. If the plan does not match CU then you have to forfeit any deferrals that are reclassed to CU. My question is are the amounts allowed to be CU? Does the plan use the 402g limit as the max or a % defined by plan as the max deferral before CU? Does the plan allow you to reclass to CU any amounts that fail the test.

I know, it is the standard answer - What does the Plan allow?

JanetM CPA, MBA

Posted
If the plan does not match CU then you have to forfeit any deferrals that are reclassed to CU.

Do you mean match?

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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