Jump to content

Recommended Posts

Posted

A plan’s sponsor wants to provide an automatic-contribution arrangement for some specified classes of non-highly-compensated employees, but not others.  (All highly-compensated employees would be excluded.)

May a plan provide this without tripping on a tax-qualification condition?

Is it feasible to provide this using an IRS-preapproved document without losing reliance on its IRS letter?

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted

Thank you for the quick and clear help.

Lacking a § 414(w) “undo” distribution for those who had been inattentive makes an automatic-contribution arrangement a non-starter.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted

It's my view (and I've seen others within my company and elsewhere agree) that automatic enrollment is not a benefit, right or feature subject to non-discrimination testing.  So that eliminates another barrier if one implements auto enrollment for only some eligible employees in a plan.

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now
×
×
  • Create New...

Important Information

Terms of Use