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Cycle 3 Discretionary Match - When is the first notice due?


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Posted

Plan adopted a Cycle 3 restatement in Dec 2021, effective Jan 1 2022. 

Is the first required discretionary match notice due for the 2022 plan year, or for 2023? 

R. Alexander

Posted

Ours (IRS pre-approved) specifically states that it is due for the plan year beginning AFTER the end of the plan year in which the document was adopted. So, assume calendar year plan, adopted in 2021, it would be due for the 2022 plan year. If adopted in 2022, then need to do one for the 2023 plan year.

Posted
55 minutes ago, Belgarath said:

Ours (IRS pre-approved) specifically states that it is due for the plan year beginning AFTER the end of the plan year in which the document was adopted. So, assume calendar year plan, adopted in 2021, it would be due for the 2022 plan year. If adopted in 2022, then need to do one for the 2023 plan year.

And remember, there is no IRS model notice, this is basically good faith compliance.  I highly doubt that the IRS will come after anyone following their document providers guidance on this issue, whether that is in the year adopted or the year after adoption.

 

 

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