Use of Self Correction

[Dougsbpc]

Section 305 of Secure Act 2.0 seems to greatly expand the use of Self-Correction of plan errors. This is a good thing.

It appears to also allow for the self-correction of significant demographic errors like failing a 401(a)4 Nondiscrimination test. The confusing part of this is where it indicates that the plan must follow the correction methods and procedures of 1.401(a)4-11g . One of the requirements of 11g is that the correction is made by the 15th day after the 9th month following the close of the plan year (October 15). However, 305 of the Secure Act 2.0 allows for correction by the 18th month after discovery of the plan failure.

Suppose you have a 12/31/2024 plan year end and it is discovered on 12/15/2025 that the plan sponsor did not execute (inadvertently) the 11g amendment provided to them on 10/1/2025. To me, this would be the failure and this failure was discovered 12/15/2025 and would need to be corrected under Self Correction by 6/15/2027 (18 months). Actually, what happened here was that the plan sponsor funded the extra $765 to a participant before the 10/15/2025 date but inadvertently set aside the amendment and did not sign it by the 10/15/2025 date.

What do you think applies to be able to Self Correct the error?  the 11g amendment requirement itself that the amendment be executed by 10/15/2025 or the overall Self Correction requirement that the amendment be executed by 18 months after the discovery of the failure (despite having funded the additional contribution before 10/15/2025)?

Thanks.