operational failure

[doombuggy]

We are taking over a client from {redacted}.  Their plan document indicated that for purposes of elective deferrals, compensation shall not include bonuses.  When we asked the client for bonus data for 2017, they responded that they have never excluded bonus from comp.  I do not see a 414s test in what little we got from {redacted}.  I don't know the details of who got bonuses, and the plan has 1 HCE (one of the owners, the other two owners don't "work" there/receive no comp).  How would the plan sponsor go back and correct prior years thru the self correction process?

[Mike Preston]

Way too early in the process to definitively say there is anything to correct.  Also, need to clarify a bit.  "For purposes of elective deferrals" can mean different things.  Does it mean that a participant may not defer from bonuses?  Or something else?  Did anybody actually defer from bonuses?  So many questions.....