Missed deferral election - Auto Enrollment Plan

[Gilmore]

EPCRS says if a deferral election is not started in an auto enrollment plan, a QNEC can be avoided if the election is started by: 

"(i) Correct deferrals begin no later than the earlier of the first payment of compensation made on or after the last day of the 9 1/2-month period after the end of the plan year in which the failure first occurred for the affected eligible employee or, if the Plan Sponsor was notified of the failure by the affected eligible employee, the first payment of compensation made on or after the end of the month after the month of notification;"

Say a plan with auto enrollment has payrolls the 15th and the last day of the month.  A participant is supposed to be auto enrolled on January 1, 2021, but is not.  The participant finally notices and informs the plan sponsor on June 1, 2021. 

When must the deferrals begin to avoid the QNEC? 

The month of notification is June.  The month after the month of notification would be July.  Since there would be a payroll on "the end of the month after the month of notification" (July 31, 2021), is that the payroll date that deferrals must start?

What if the last payroll in July was July 25, 2021, would the deferrals need to start with the first payroll in August, which would be the first payroll "on or AFTER" the end of the month after the month of notification?

Thanks very much.

[Mike Preston]

Yes. Yes.

[Gilmore]

Thank you.