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Posted

SH Match plan has an initial auto deferral of 0%. The autoescalation is 2% each year. Other than defying the logic of having an ACA in the first year of participation, can the autodefrral rate be 0%? Thanks.

Posted

It "may", but not qualify for the Safe Harbor. I think it must be between 3% and 10% for the Safe Harbor. Other than that, the only requirement for the ACA is that ample time is given for the employee to raise, reduce, or totally elimiate their rate of deferral.

Good Luck!

CPC, QPA, QKA, TGPC, ERPA

Posted

ETK, it's not a QACA because the SH match is only up to the first 4% of deferral (enhanced SHMAC). Makes no sense, but doesn't seem wrong for now. I have to amend the plan for other reasons, effective 1/1/14 and will likely change this provision.

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