Peter Gulia Posted February 16, 2023 Posted February 16, 2023 An individual-account (defined-contribution) plan has no nonelective contribution and no matching contribution, only a participant’s elective deferrals. The plan allows participants a choice between non-Roth and Roth deferrals. After qualified military service, a reemployed participant invokes her right to make her contribution regarding the time she was away on military service. The participant’s wages are not enough to support her current-year deferrals and extra reductions for prior years’ deferrals. Fortunately, the reemployed person has savings. For the prior years’ deferrals, she sends her personal check to the plan’s recordkeeper/trustee. The participant asks that her make-up contribution be credited to her plan account’s Roth subaccount. Is there any reason the plan would not do this? Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
AMDG Posted February 17, 2023 Posted February 17, 2023 FWIW, as an anonymous contributor, I can't think of any -- other than to make sure that the plan allowed for Roth elective deferrals in all years for which the make-up contributions relate.
Peter Gulia Posted February 17, 2023 Author Posted February 17, 2023 AMDG, thank you for your good help. And we see that it matters not only whether the plan now allows Roth deferrals but also whether the plan allowed Roth deferrals for the past periods. BenefitsLink neighbors, here’s my follow-up question: Should a participant who pays her make-up contribution by her personal check always prefer to designate that deferral as a Roth deferral? Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
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