30Rock Posted January 2, 2013 Posted January 2, 2013 What is the correction for a safe harbor plan that in years prior to 2012 calculated the safe harbor match on annual pay rather than pay period? They remitted the safe harbor each pay period but then at the end of the year remitted a true up contribution because at one time prior to 2005 I think the plan was at a prior vendor and the document did allow this annualized pay. The plan then switched to payroll based until 2012 when it was amended to use annual. They now want to correct the prior years. Does this blow up the safe harbor and ADP and ACP testing is needed, or can we just forfeit the excess match, which of course is not that easy since some employees have terminated. Thoughts!
QDROphile Posted January 2, 2013 Posted January 2, 2013 Perhaps the most civilized and practical thing to do is amend retroactively to provide for a true-up.
30Rock Posted January 15, 2013 Author Posted January 15, 2013 So this would require a VCP filing I believe!
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