Missed Catch Up Contribution - Rev Proc 2015-28

[52626]

Payroll provided stopped the deferral at $18,000. However, the participant is over 50 and had changed his deferral percentage in June 2015 so that by the time the last payroll of 2015 he would have deferred the max.

Payroll issue has been corrected so going forward deferrals will continue for participants catch up eligible.

the fist payroll since hitting the 402(g) limit there was no withholding. The employer has set up the catch up contribution to begin with the next payroll check.

Client is concerned about missing the withholding the first payroll following the $18,000 limit.

Am I correct in saying Rev Proc 2015-28 provides relief to the employer since the error was brought to their attention by the participant and the employer implemented the withholding to start the next payroll period??

No QNEC is required. Since this is a 3% Non Elective Safe Harbor, no match is required to be made.

This is not an auto enrollment plan.

thoughts??