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Posted

Participant completed and timely turned in the enrollment form. Deferral election was properly entered into payroll however enrollment form was not forwarded to vendor for investment election set up. Consequently participant was default enrolled for investment when deposits arrived. Contributions have been made timely since June to the participant account in the default investment.

Any one know if there is a stated correction or example correction for this error? Since it isn't a missed deferral opportunity I couldn't find anything on point. Is there even a required correction? It seems there would have to be because the Client made the error.

Client would like to compare earnings from default investment with the earnings from the participant investment choices and make a corrective contribution for the difference, if applicable, which sounds reasonable. That will "put the participant in the position he/she would have been in had the error not occured".

thoughts?

Posted

Your analysis sounds correct.

Deposit of lost earnings, if any, for not following investment direction would seem the appropriate fix.

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