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Posted

I just want to make sure I'm reading this correctly in the Plan Document for a client.  Here is the excerpt, regarding the true-up for the Safe Harbor Match:

Notwithstanding the foregoing, if the Employer elects to contribute and allocate separately ADP Safe Harbor Matching
Contributions for an Allocation Period of less than the Plan Year, a true-up will be required unless ADP Safe
Harbor Matching Contributions with respect to any Elective Contributions made during a Plan Year quarter are
contributed to the Plan by the last day of the immediately following Plan Year quarter.

So if the client is funding the match on a payroll-by-payroll basis, a true-up for shortages is not required correct?

Posted

I think what that's less-than-simply saying is, if the plan doesn't make its "computed more frequently than annually" match by the end of the next quarter (as we normally see required with pay period match computations), then by failing on that timing provision, the plan is essentially falling back into an annual computation and the true-up would be required. 

(Which makes sense because the plan would have bailed on its obligation as a pay-period calculator....and an annual calculation is what then leads to needing true-ups in the first place.)

Posted

I concur with Bri's comment.  Assuming that the payroll funding was correctly computed on that basis, you should be fine.

 

Having braved the blizzard, I take a moment to contemplate the meaning of life. Should I really be riding in such cold? Why are my goggles covered with a thin layer of ice? Will this effect coverage testing?

QPA, QKA

Posted

Ask the document provider.  They wrote it.

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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