t.haley Posted January 10, 2017 Posted January 10, 2017 What is the correction for failure to implement auto enrollment in 401k plan where the employee has since temrinated? For example, Employee A was hired in 2014 and eligible for auto enrollment. Employee A was not auto enrolled and continued working until 2015. The error was discovered in 2016. I am aware of the correction procedure in Rev Proc 2015-28 but it requires "correct deferrals" to begin within a certain time period. We cannot do this because there is no compensation for this employee. Which brings me to the general correction for exclusion of an eligible employee - 50% QNEC. How is this contribution made? There is no plan account - is one created and then distributed to the former employee? Any advice is appreciated!
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