Deadline for distributing deferrals to correct 415 limit?

[Richard Anderson]

Assuming a "reasonable error", is there a deadline (similar to March 15 for excess contributions and April 15 for excess deferrals) for distributing deferrals to correct excess annual additions? If there is a deadline, what are the consequences of distributing after the deadline?

We just received census information on a 1999 calendar year plan in which one participant deferred 31%.

[Guest mo again]

As far as I know, there isn't a hard-coded deadline. However, because of the impact of 415 excesses on ADP/ACP testing, as a practical matter, we've always acted as though the deadline were the end of the following limitation year. I think this is arguable though.