participant not permitted to defer

[K2retire]

Employer with a standardized prototype plan has 1 Year of Service requirement for eligibility. The employer mistakenly believed that eligibility must be met each year, and when an employee cut back to less than 20 hour per week work schedule, the employer told them they could no longer defer. Seven months later the employer has asked us how to fix this. Would this fall under the EPCRS correction requiring the employer to make a QNEC for the lost deferral opportunity?

[Bill Presson]

Employer with a standardized prototype plan has 1 Year of Service requirement for eligibility. The employer mistakenly believed that eligibility must be met each year, and when an employee cut back to less than 20 hour per week work schedule, the employer told them they could no longer defer. Seven months later the employer has asked us how to fix this. Would this fall under the EPCRS correction requiring the employer to make a QNEC for the lost deferral opportunity?

Yep.