OFF Calendar Plan Year and 402g Limits

Plan is on an off-calendar plan year 10/1/2020 - 09/30/2021

Participant defers $34,500 during the plan year - divided as follows:  18,000 from 10/1/ through 12/31/2020 & 16,500 from 01/01/2021 through March 31, 2021 when he quit.

Does he have a 402g issue or is he ok.  He was not in another plan before this one during 2020.  However, we do not know what he did after he quit.  Thoughts??

402g limit is calendar year.  So no issues.

2020: 18,000.  less than 19,500. all good

2021: 16,500.  less than 19,500. all good

The participant will need to keep an eye out for 402g limit if deferring into another plan.  Shouldn't be an issue with you as long as new employer is not related to old employer.

Thanks just wanted confirmation! 

The answer above assume there were no deferrals from 1/1/2020 to 9/30/2020.  You could have a problem if there was more than $1,500 in deferrals from 1/1/2020 to 9/30/2020.   Since the 402g is calendar year limit you need to know how much was deferred from 1/1/2020 to 9/30/2020 to know if you are good for 2020. 

Ok, I will admit it has been a number of years since I worked on 4k plans but I am pretty sure I have a valid point.  Tell me if anyone thinks I don't. 

Valid point.  I made the assumption that there were no deferrals from 1/1/2020 to 9/30/2020....

When I was doing more training in the early days of 401(k), we used to say that the Participant carries the 402(g) limit "on his/ her back."  Trying to stress that this is a calendar year limit which applies to the Participant. (Ignoring for the moment that the plan document may have language concerning notification and distribution of excess.) As noted above, the Plan's Year is irrelevant to this particular item.

I am tempted to try and talk  call all my Off Cal sponsors and try to talk them into becoming calendar years.  I may even just do the short year for free!  lol