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Posted

A plan failed the ACP Test for the plan year ending 12/31/2014. There was a ACP refund due to to be given to HCE Randy. The refund amount of 117.18 (110.98 plus 6.20 earnings). The prior admin (we recently took over this plan) "corrected" by sending the 117.18 to the forfeiture account. I am not sure when in 2015 this was done. This amount should have been sent to HCE Randy. What is the correction from here?



Can we simply move the amount out of forfeiture and back into his plan and then process the distribution to the participant? Or, Do we need to do a QNEC or One to One?


Posted

Duplicate post in another Forum. Reponses are posted in:
http://benefitslink.com/boards/index.php/topic/59483-acp-refund-correction-method/

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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