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include excess deferrals in avg. benefit % test


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Guest ksumner
Posted

Should we include 401(k) and 401(m) excess deferrals and match do to failure of the ADP/ACP tests in the Average Benefit Percentage Test for 401(a)(4)?

Posted

When a plan fails ADP/ACP test the 'contribution' is not returned, but rather 'distributed' to the participant.

In other words, it is still a contribution and used in testing.

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