QACA's and Permissible Withdraw

[Guest frosty]

Does the permissible withdrawal feature that applies to EACA's also apply to QACA's? I've been reading the Regs and Sal Tripodi's info but don't think it is is an option.

[DMcGovern]

Does the permissible withdrawal feature that applies to EACA's also apply to QACA's? I've been reading the Regs and Sal Tripodi's info but don't think it is is an option.

only if it also qualifies as an EACA

[Guest frosty]

Thanks for the response. I read that as well, but I'm a little confused as to why/how it could be both?

[DMcGovern]

Thanks for the response. I read that as well, but I'm a little confused as to why/how it could be both?

the plan would have to have a QDIA and follow all of those rules (notices, etc)

[VTPension]

So a QACA that has a QDIA so that it is also an EACA can have the 90 day permissible withdrawal?

I have gotten conflisting answers from 2 sources so I am hoping for a tie breaker.

thanks

[DMcGovern]

So a QACA that has a QDIA so that it is also an EACA can have the 90 day permissible withdrawal?

I have gotten conflisting answers from 2 sources so I am hoping for a tie breaker.

thanks

It is my understanding that the regulations in Code sections 401(k)(13) for QACAs and 414(w) for EACAs provide for these automatic contribution arrangements. Under both, they have the notice requirements and the qualified default investment requirement. They also provide for participants to have the 90-day window period to withdraw the contributions. (As opposed to a regular automatic enrollment feature that does not provide this 90-day window.)

I have a brief summary of the three different types of automatic enrollments - attached. It doesn't cover everything about them, but it shows some of the differences. Maybe someone else can add their information to help you.

Good luck!

comparison_of_3_types_of_auto_enrollment_plans.xls