DTH Posted March 10, 2014 Posted March 10, 2014 Plan excludes participants who do not elect to make 403(b) deferral of more than $200 for the plan year. There are no exclusions for purposes of employer contributions. Do you count these excluded employees as $0.00 for the ACP test? I have gotten two different answers. Yes, because they could have contributed more if they wanted to and No because they were excluded from making deferrals.
MWeddell Posted March 10, 2014 Posted March 10, 2014 I would say to include them in the 401(m) test. They are eligible to receive matching contributions if they just defer enough. Exclude them only if compensation itself was <= $200 for the year.
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