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MDO on comp exclusion spans multiple years - Do all get the 25% QNEC or are some ok at 0%


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Client has been excluding bonuses and commissions since 2024 and we know we can correct by using the 25% QNEC with the notice requirement, but some employees were not impacted until 2026. Do the participants who only had MDOs in 2026 also get the 25% QNEC (similarly situated comes to mind) or can the 0% QNEC apply if they only had MDOs in 2026?

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