Early Inclusion Amendment - Adoption Date

[msmith]

For a 2017 calendar Plan Year, what is the latest possible date to adopt a corrective amendment to permit early entry for an employee that did not meet eligibility (non-highly compensated)?

[Larry Starr]

A --11g amendment can accomplish that; it can be adopted up to the 15th day of the 10th month after the year end. That' 10/15 for a calendar year plan.

[msmith]

Thank you, Larry. I thought that was the date - but started thinking too much and thought that was for a Coverage correction.

 

 

[Larry Starr]

3 hours ago, msmith said:

Thank you, Larry. I thought that was the date - but started thinking too much and thought that was for a Coverage correction.

 

 

-11g is not limited in what it can be used for.

[ACK]

EPCRS allows self correction by plan amendment with respect to the early inclusion of otherwise ineligible employees.  (Section 2.07 of Appendix B).  SCP allows correction any time for insignificant errors, or by the end of the 2nd year after the year of failure for significant errors.