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Posted

Plan has QACA Match, so changing to SH Match effective 7/1 would be an amendment that increases everyone's match for the whole year.  Do we think this is possible?  The primary objective is to eliminate the auto enrollment.

Austin Powers, CPA, QPA, ERPA

Posted

I would think the match formula would have to retroactive to the beginning of the plan year (Jan 1 if calendar year), and on a full year basis. The removal of the auto enroll would have to be prospective (July 1 in your example) I would think.
it does not address the auto enroll question you have, but example 2 speaks to the match increase. https://www.irs.gov/retirement-plans/mid-year-changes-to-safe-harbor-plans-or-safe-harbor-notices

I am undecided on the auto enroll part, which of course is linked to the match when its a QACA. I hope brighter minds give you their take. 

I'm a stranger on the internet. Nothing I write is tax or legal advice. 

I'd like a witty saying here, but I don't have any. When in doubt, what does the plan document say?

Posted

This is the text from the link justanotheradmin posted. Notice 2016-16 doesn't say "or vice versa" in the final bullet point below, but the commentary on the website does. 

 

Prohibited mid-year changes

The Notice provides the following list of “prohibited mid-year changes” that may not be made to a safe harbor plan, unless the change is required by applicable law or court decision.

  • A mid-year change increasing the years of service for the vesting schedule for a safe harbor plan consisting of a Qualified Automatic Contribution Arrangement (QACA);
  • A mid-year change to reduce or narrow the group of employees eligible to receive safe harbor contributions; however, this does not limit the ability of the employer to amend a plan mid-year to change eligibility service crediting rules or entry date rules for employees who have not yet become eligible to receive safe harbor contributions;
  • A mid-year change to the type of safe harbor, for example, a change from a traditional safe harbor to a QACA, or vice versa;
Posted

That rule is limited just to new plans thank goodness. Any plan adopted after 12/29/2022 is subject to the new mandatory auto enrollment but no others (at least for now).

Austin Powers, CPA, QPA, ERPA

Posted
On 5/19/2023 at 9:24 PM, austin3515 said:

That rule is limited just to new plans thank goodness. Any plan adopted after 12/29/2022 is subject to the new mandatory auto enrollment but no others (at least for now).

Nevermind. Still don't have all the rules straight in my mind.

William C. Presson, ERPA, QPA, QKA
bill.presson@gmail.com
C 205.994.4070

 

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