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Payroll glitch causes incorrect deferral/match withholdings


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The participant was deferring at 3% for the year. In December, the payroll company's system caused a change in his deferral from 3% to $3.00. This continued into January and also affected his match. Am I correct that for 2011, the company needs to make a QNEC of 50% of the missed deferral amount, plus earnings, plus applicable match and earnings? But for 2012, they can choose to do nothing since the participant can still recapture this missed deferral over the course of the remaining 11 months? Is the client limited to a QNEC of 50% for 2011 or can the QNEC equal the total amount missed? Thanks.

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