cpc0506 Posted September 18, 2015 Posted September 18, 2015 It is discovered in checking the 2014 vaulation work for a DC plan that there were a few employees who should have entered the plan in the 2013 plan year. In calculating lost opportunity, can we rely on Rev Proc 2015-28 with the reduced QNEC of 25% of missed salary deferral for the 2013 and 2014 failures? What if the employee was missed in 2012 and 2013 and 2014? Are we required to calculate the full QNEC (half of missed salary deferral) for all years missed? Or does Rev Proc 2015-28 give us the ability to reduce the 2013 and 2014 QNEC and we only need to give the full QNEC for 2012? Any guidance would be helpful.
Mike Preston Posted September 18, 2015 Posted September 18, 2015 Why wouldn't 2015-28 apply to all years?
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