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Posted

A governmental employer sponsors a 401(a) defined contribution plan, a 401(K) plan, and a 457 (b) plan.  For purposes of the annual contribution limits under 415 (c), are the 457 (b) plan contributions treated separately, or are they combined with the 401(k) and 401(a) contributions?

Posted

They are treated separately for purposes of the 415(c) limits.  Of course, deferrals under 401(k) and 403(b) plans of separate employers are aggregated for purposes of the 402(g) limits.  457(b) plans are subject to separate limits, regardless of whether it is one employer or more than one.  (And of course, a state or local government can't have a 401(k) at all unless it is a grandfathered 401(k).)

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Posted

Regarding deferrals, does that mean combined deferrals to the 401(k) and 457 (b) plans cannot exceed $20,500 for 2022?  I thought an employee could defer $20,500 to each plan for a total of $41,000.  The 401(k) is grandfathered, so this is a bit of an odd case.  Strange the employer has a 401(k) and 457 plan.

 

Posted
22 hours ago, luissaha said:

Regarding deferrals, does that mean combined deferrals to the 401(k) and 457 (b) plans cannot exceed $20,500 for 2022?  I thought an employee could defer $20,500 to each plan for a total of $41,000.  The 401(k) is grandfathered, so this is a bit of an odd case.  Strange the employer has a 401(k) and 457 plan.

 

Not combined for deferrals under 402(g). They can double up.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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