Should we amend 5500 or make QNEC

[pam@bbm]

We have a 401k plan with employer contributions of safe harbor non-elective and additional profit sharing. The plan has a November 30 year end. While completing the 11/30/2015 year end administration, it was discovered that the employer failed to provide census information for 2 employees for the prior year of 11/30/2014. Both employees had met eligibility to enter the plan during the 11/30/2014 plan year and should have received employer contributions.

We are calculating a QNEC for the missed deferral opportunity. But for the missed employer contributions, should we amend the 11/30/2014 year's 5500 or compute a QNEC to be included in the 11/30/2015 5500?.

Thank you for your thoughts.

[Flyboyjohn]

Our firm's practice is to include corrective contributions for a prior year in the current year 5500 and not amend the prior year 5500. But if it's an audited plan you might want to bounce it off the auditor for their position.

[Tom Poje]

most of the time we submit 5500s on a cash basis so missed contributions as well as receivables don't show until they are actually made anyway.