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Participant should have entered plan 4/1/10, but actually was notified on 10/1/10, began Roth deferral contributions of 15% at that point. The Plan is a safe harbor non-elective 3%, which was calculated correctly for 2010. In reading the correction for the missed deferrals the employer will have to make up a QNEC for the 4/1/10 thru 10/1/10 of 50% of the compensation for that period.

My question is regarding what contribution percentage to use in calculating the QNEC since it is a safe harbor plan. Would I use his elected 15%, the plans ADP percentage or 3% since it is a safe harbor non-elective plan? Also, I didn't see anything extra that I needed to do since his deferrals were Roth, or did I miss reading it?

Thanks all,

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