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Posted

Client instructs participants to make elective contribution changes in their payroll system.

In error, the online elective contribution change feature was activated on the record-keeper's website.

Several participants made elective contribution changes on the record-keeper's website despite instruction from the plan sponsor to only make changes in the payroll system.

Does the sponsor need to recognize the changes on the record-keeper's website?

Thanks in advance for anyone's thoughts on this!

Posted

Whose error activated the record keeper’s election function?  When did the activation occur relative to instructions for elective deferrals?

Describe how the instructions to the payroll system election function were presented to participants and eligible employees.  For example, were the  instructions to use the payroll election function in the SPD?  Elsewhere?  What else are employees instructed to do through the payroll system?

What record keeper functions were officially usable by participants and how was the sanctioned use presented? Investment instructions?

Who is the plan administrator and what role did/does the PA have in any of the policies and communications relating to participant elections of all sorts (e.g. beneficiary designations)?

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