Ineligible EE deferred and rolled over, then term'd

[Cynchbeast]

Employee deferred in 2016 & 2017, rolled over large amount ($182k), then terminated in 06/2017 and rolled over all money to an IRA.  She wasn't eligible until 07/01/17.  Will look into retroactive amendment to make her (and others?) eligible; alternatively I am thinking:

• $182k rolled into plan ended up back in an IRA so net result is same as if had never gone into plan
• $1,136 deferrals were in 2016 and $4,498 were in 2017 and both ended up in an IRA.  Since she was withing IRA limits for each year (assuming she didn't have other IRA contributions), net result again is same as if she had just put into IRA and not into plan

Given above, we should just be able to document all this and consider issue self-corrected.

Thoughts?

[ETA Consulting LLC]

No :-)

Good Luck!