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For employees who fail to affirmatively elect a deferral rate, and are automatically enrolled at the plan's default percentage, how does the employer apply the default percent to tips received as cash to the employee? 

I understand excluding cash tips from plan compensation has its own complications, especially since most HCE do not receive tips. 

I am not asking about how to employees defer from tips when they affirmatively make an election - those employees can turn in their tips each shift if their expected net pay is not large enough to cover the elected deferral amount. 

I am wondering specifically what guidance or advice folks have been given sponsors who have to implement an EACA or better (most of ours go with QACA), in light of the auto enroll mandate in SECURE 2.0. 

If there is another thread on this somewhere, please feel free to share, I wasn't able to find anything recent, but perhaps did not use the right search terms. 

Thanks!

I'm a stranger on the internet. Nothing I write is tax or legal advice. 

I'd like a witty saying here, but I don't have any. When in doubt, what does the plan document say?

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