dragondon Posted October 31, 2022 Posted October 31, 2022 If the administrator inputted the incorrect % match for a participant how can they correct this error? The plan is matched on a paycheck by paycheck basis so is there a way to correct it in the following paycheck or would that not be allowed? If that does not work would we be able to have a forfeiture of that amount or is the money now the participants due to the error?
Lou S. Posted October 31, 2022 Posted October 31, 2022 Remove from the affected participant account (along with associated gain/(loss)) to a plan holding account and use to offset future matching deposits. Participant is not entitled to data entry error in their favor. Luke Bailey 1
dragondon Posted November 1, 2022 Author Posted November 1, 2022 Thanks Lou, Should the plan doc specify how this will be handled for every plan?
CuseFan Posted November 1, 2022 Posted November 1, 2022 23 hours ago, Lou S. said: Participant is not entitled to data entry error in their favor. Yes, this isn't Monopoly (no bank error in your favor)! acm_acm, Luke Bailey and MDCPA 3 Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
rocknrolls2 Posted November 1, 2022 Posted November 1, 2022 I disagree with CuseFan only to the extent he says that the plan document should say how the correction will be handled. I agree with him and others who are saying to the extent that the error should be corrected for the reasons that they expreseed. I am fine with language authorizing the plan administrator to correct any error in administration by referencing EPCRS generally. However, I would not want the plan document to effectively tie the administrator's hands to a one-size-fits-all solution intended to work for every situation so that there is some degree of flexibility on the part of the plan administrator. If that one solution does not work in a particular instance and the plan administrator uses a different correction approach that is more appropriate, but contrary to the plan's language, this in itself gives rise to an operational error. Luke Bailey, acm_acm and Bri 3
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