Match True UP

[52626]

1. Effective 9/1/2018 company a acquired a group of employees from company b

2. The plan was amended to  allow the employees employed on 9/1 would be eligible to join company a's plan immediately.

3. Payroll is twice a month.

4. Due to some payroll issues, deferral withholdings began with the 9/30 payroll. Match is made each payroll period.

5. the plan makes a true up at  year end.

Question.

Must the plan include the wages earned for the first payroll (9/15) even though deferrals  did not begin until 9/30? Needless to say if the 9/15 wages are included in the true up, these employees will have an additional match due.

Although the document has an effective date of 9/1 since deferrals could not begin until 9/30 is there is issue if the 9/15 wages are excluded when determining the true up match???

[Lou S.]

What is your Plan's definition of compensation? Does it exclude pre-participation comp?

[Bri]

Wait until the "failure to implement the deferral elections" for 9/15 issue comes into play, too!  This'll be fun....

[Luke Bailey]

Seems to me like Bri has the answer.