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415 Excess Suspense Account


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Have a 401(k) Plan which does NOT provide for return of ee salary deferrals in the event of a "415 excess" - uses the "415 excess suspense account" approach.

Participant incurred a 415 excess for the 1998 plan year (employer made a large PS contribution). A "415 excess suspense account" was created for this participant, which presumably would be allocated as part of the 1999 PS contribution. However, a PS contribution was NOT made for 1999 plan year.

Is the "415 excess suspense account" allocated to this participant for the 1999 plan year (despite the fact that no PS contribution was made), or does it continue to be held in suspense until the employer makes a PS contribution?

Document (CORBEL volume submitter) does not address this specific situation.

Anyone with prior experience and/or any thoughts? Thanks!

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