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A client wishes to allow a separate deferral election on their bonus election. No problem there but they also offer auto-enrollment and escalation. The recordkeeper can not escalate the bonus election. So it will be set at the auto-enrollment rate on an evergreen basis absent any changes while the normal rate escalates up to 10% unless the participant opts out.

This plan is not a QACA but does this feature disqualify them from being considered an EACA? I am just concerned it violates the uniformity requirement regarding deferral elections. Thoughts?

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