nancy Posted October 21, 2013 Posted October 21, 2013 We have a plan that failed the ADP test for 2011. Corrective distributions were made by 12/31/2012. However, we discovered today that there was a miscalculation in the earnings portion of the corrections. Therefore one HCE needs to receive an additional $109. The other HCE actually received $3 too much. We are going to distribute the $109 immediately, but now the question is, did we fail to make the corrections within the first 12 month period. It seems very punitive to have to make a one-to-one contribution for this minor error (which would result in less than $2/participant) and it also seems a little over board to go to VCP for $109. To make matters worse, the client is moving to another TPA and this was discovered as we were reviewing the takeover files being sent. Any suggestions?
BG5150 Posted October 22, 2013 Posted October 22, 2013 I'd just self-correct and move on. (I would, however, adjust that $109 with earnings from when the original refund was done). QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
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