msmith Posted December 27, 2019 Posted December 27, 2019 A Plan Sponsor's Payroll Company processed a participant's deferral change in July 2018. For some unknown reason they stopped the deferral as of July 2019. There reason is it was an "anniversary election" - wait....what!!! So now it is December 2019; and the participant has not had deferrals withheld from pay since July 2019. I have instructed the Plan Sponsor about the correction method to use. However, if the participant can still defer the maximum for 2019 from the final 2019 bonus paycheck, is the QNEC still necessary?
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