Elect Def Failures (RP 2015-28)

[austin3515]

With respect to the auto enrollment failuires in this procedure, it says you "may use" the default investment fund. Can you still use the DOL's lost interest calculator?

I'm just envisioning a correction involving 15 people where you have to look up their fund based on their DOB and get all the invidiualized returns for each date range, for a fund whose performance might not be publicly available on yahoo because it's an insurance company wrap. This sounds like a horrible nightmare...

From 2015-28 (emphasis added by me):

(2) Calculation of Earnings for certain failures to implement automatic contribution features. This revenue procedure provides an alternative safe harbor method for calculating Earnings for Employee Elective Deferral Failures under § 401(k) plans or § 403(b) Plans that have automatic contribution features and that are corrected in accordance with the procedures in section 3.02(1) or 3.03 of this revenue procedure. If an affected eligible employee has not affirmatively designated an investment alternative, missed Earnings may be calculated based on the plan’s default investment alternative, provided that, with respect to a correction made in accordance with the procedures in section 3.02(1) of this revenue procedure, any cumulative losses reflected in the Earnings calculation will not result in a reduction in the required corrective contributions relating to any matching contributions.