Safe Harbor Match change

[R. Butler]

Safe Harbor plan, match calculated over the entire plan year. Plan sponsor wants to change to each payroll epriod mid-year. Can that be done? My inclination is no, but I'm not positive.

Thank you in advance for any guidance.

[Tom Poje]

I'd lean toward a big no.

the first implies there is a true up,

the second inplies no true.

thus the possibility exists (whether it happened or not shouldn't matter) that someone could have deferred the max already, but hasn't gotten the true up yet.

if you switch mid year, then the rate of match would be different

[Kevin C]

If you are asking about changing the SH match calcuation mid-year to payroll by payroll with no true-up, I'd say definitely no. See the 2nd sentence of 1.401(k)-3(e)(1).

If they are only wanting to change the deposit timing, the answer might be different.