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Posted

A plan sponsor was able to make a contribution totaling less than $500 under SCP in order to satisfy a missed deferral opportunity for deferrals not withheld from some OT paid to a few participants. The contribution included the missed match and a very small amount of earnings. NO 415 violations were discovered either. The missed deferral opportunity was discovered after the close of the plan year, but prior to filing the 5500. Should the contribution be included on the 5500 for the plan year it represents or the current plan year and can the whole contribution be deposited into the deferral account? It is a safe harbor matching plan and in some instances the missed deferral opportunity amounted to a few dollars or even less.

Thanks

Posted

Does the plan's administrator report its Form 5500 using cash accounting or accrual accounting?

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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