Pixie Posted March 13, 2014 Share Posted March 13, 2014 Participant takes hardship in September 2013. The employee deferrals are not suspended. What is the best way to self correct? Should we suspend future deferrals or should we return past deferrals as a mistake in fact and then have the client run them through payroll. Or should we return the deferrals and tax them with the 10% early withdrawal. The confusing thing is that we span 2 calendar years. Thank you! Link to comment Share on other sites More sharing options...
Guest A_Dude Posted March 13, 2014 Share Posted March 13, 2014 I haven't looked anything up, but I feel like this is the plans error too and not just the participant for informing that they were still deferring. Could you kick it to a forfeiture, and then back pay the participant for the difference if they had not deferred? I'm sure this has happened before and there is some sort of guidance... Link to comment Share on other sites More sharing options...
WCC Posted March 13, 2014 Share Posted March 13, 2014 This is a good reference. Page 33 references your situation. EPCRS: Correcting 401(k) Plan Mistakes – Two Sessions - July 25, 2013 - (transcript) - Discussed correcting common 401(k) plan mistakes under EPCRS Revenue Procedure 2013-12, and how to find, fix and avoid them.Handout: EPCRS: Correcting 401(k) Plan Mistakes presentation Link to comment Share on other sites More sharing options...
Recommended Posts
Create an account or sign in to comment
You need to be a member in order to leave a comment
Create an account
Sign up for a new account in our community. It's easy!
Register a new accountSign in
Already have an account? Sign in here.
Sign In Now