Do recordkeepers segregate condition-of-employment contributions from elective deferrals?

[Peter Gulia]

Some § 403(b) plans provide a participant’s contribution that, although made by salary reduction, is not an elective deferral because the contribution is made as a condition of employment. (Some IRS-preapproved documents set up a specially defined term for such a Mandatory Contribution.)

Internal Revenue Code § 414(v)(7)’s constraint that a higher-wage participant’s “additional elective deferrals” must be non-Roth contributions applies only regarding elective deferrals.

If an employer’s information feed to a recordkeeper carefully shows distinct amounts for each of Mandatory Contributions and elective deferrals, does a recordkeeper record these in distinct subaccounts?

Or, should an employer worry that a recordkeeper might flag as § 414(v)(7)-burdened many participants whose elective deferrals did not exceed the without-catch-up limit?

About this, are some recordkeepers better than others? For example, does TIAA—because of its wide experience with higher-education employers, many of which provide these condition-of-employment contributions—handle this more capably than other big recordkeepers?