Is this De Minimis or does it need to be corrected?

[Guest RobBobBobby]

In 2012 a participant had a 3% pretax election however ony 1% was withheld so a an additional $50 needed to be taken to true it up.

Two pay periods later an additional deferral was taken and made to the trust however it was $4 sort.

Not that his has been now discovered in 2013 my question is if this is de minimus or should 50% of the missed defferal be made and a corresponding lost earnings correction?

Thoughts?

[Bird]

If the net error is $4 it's de minimis in my book.

[BG5150]

EPCRS says no corrective contrib is too small. Distributions, yes, but not contributions.

And it looks like the net error is $54, so a $27 QNEC plus earnings and full match on the $54 (not a QMAC) to be made if applicable.

[IRA]

What if the corrective contribution (including earnings) is less than $75, is less than the cost of distribution, and the participant has terminated and taken a full distribution. What do you with the $75 that you have to put in the plan but don't have to distribute?

[401 Chaos]

I have a similar situation so just want to be sure I understand the proper response to IRA. My understanding was that the exception for de minimis distributions was for true mistakes in required distribution amounts from contributions properly in the plan. If the correct amounts never went into the plan, however, then the exception would not extend to corrective contributions even if they are likely to be cashed out / distributed to former employees once added into the plan. Is that a correct interpretation?