EBP Guy Posted September 20, 2023 Posted September 20, 2023 Hello! Just recently found this forum and there are some good thinkers floating around. We have a plan where the ER match was incorrectly being applied to both Pre-Tax Employee Contributions and Roth Contributions. Essentially, they match 50% up to 6% of employee compensation, but an additional 1.5% was being additionally (and incorrectly) applied to the Roth contributions above the 6% mark. What are the proposed fixes for this for purposes of the audit? We were initially thinking potential corrective distributions or some kind of reversal of the match by offsetting future ER contributions. Are there any other thoughts on how to apply a fix to this? Thanks!
CuseFan Posted September 20, 2023 Posted September 20, 2023 First, as always, check the plan document to see if it says what to do regarding incorrect contributions (it may have general instructions as opposed to specific match-related issue). Absent plan instructions, I would forfeit the incorrect excess match and any related earnings, leave in the plan and use according to plan instructions. EBP Guy, Luke Bailey, Lou S. and 1 other 4 Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
BG5150 Posted September 20, 2023 Posted September 20, 2023 I agree. I don't think it's allowable to match Roth deferrals at a different rate than pre-tax. match should be calculated on the combined pre-tax and Roth as if they were one deferral. Luke Bailey 1 QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
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