BG5150 Posted December 31, 2019 Posted December 31, 2019 EPCRS calls for a 50% QNEC for failure to implement a participant election. What if the ER wants to make the person "whole" and contribute 100% of the missed deferral? I'm guessing that would be ok, because EPCRS are suggested corrections, and the participant will definitely be better off with 100% vs 50%. But what about 415? What year would that apply to? If the 50% QNEC was supposed to be $5,000 and they put in the full $10,000, what year(s) do these QNECs affect? What about for ADP testing. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
BG5150 Posted December 31, 2019 Author Posted December 31, 2019 But the 100% QNEC should be ok, right? QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
Mike Preston Posted December 31, 2019 Posted December 31, 2019 Should be, unless there is a ps cont that limits the QNEC to the 415 limit.
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