Trekker Posted January 21, 2015 Posted January 21, 2015 A non-safe harbor 401(k) plan has a September 30 year end. Employees who should have been given the opportunity to defer on October 1, 2014, were not. Employer wants to correct now and be done with it. EPCRS says the missed deferral is determined by multiplying the ADP for year of exclusion by the employee's compensation. The ADP for 9/30/15 will not be known for some time. Any suggestions on how to correct now and not wait until end of year? Thank you.
Lou S. Posted January 21, 2015 Posted January 21, 2015 Run a short year ADP test on 10/1 - latest payroll? That is the missed deferral period. If not an option, are you allowed to use prior year ADP as proxy to correct?
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