Over contributed

[Randy Watson]

We learned that a plan made errors in calculating matching contributions over a 3 year period. For two of the years, the matching contribution exceeded the amount that should have been contributed under the terms of the plan, and not enough of a match was made in the 3rd year. However, the participants received more than they should have if you add all three years together. Do we have to make a corrective contribution for the one year that participants did not receive enough or can we simply say that they received more than they should have over the course of the 3 years and not have to make a contribution for that 3rd year?

[ETA Consulting LLC]

There is, typically, some degree of flexibility in correcting operational defects. I think it is perfectly reasonable to look at making each participant whole with respect to the entire 3 year period of failure.

Good Luck!