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Posted

Pardon my senior moment, but we recently took over a new comparability profit sharing plan (no 401K option) with a 1,000 hour/last day contribution req't.

Two participants terminated in 2017 with >500 hrs, but <1,000.  The previous TPA had given these two participants a contribution for 2017.

Is this correct?

Posted

Quite possible there is a failsafe provision in the plan that creates an exception to the general eligibility requirements for one or more people who have more than 500 but less than 1,000 if necessary to satisfy 410(b). 

Posted

Or, if they were younger participants, maybe they needed to get a contribution in order to pass a4 testing.

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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