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Posted

Have a group of participants in a 401k that were brought into the plan 4/1 instead of 1/1. None of them contributed when enrolled at 4/1. What is my correction for the missed quarter. A qnec based on the quarters ADP for NHCEs? It's a calendar year plan. I believe that since I'm within the plan year and none elected to contribute there may not be a qnec. Any help appreciated.

Posted

Check Rev. Proc. 2008-50. I think as long as it is within the same year, the participants who were brought in late should be given the opportunity to contribute additional deferrals by year end. There's still an additional 9 months for them to catch up and contribute amounts that they would otherwise have wanted to contribute for the year.

Good Luck!

CPC, QPA, QKA, TGPC, ERPA

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