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A client provided a census file and we ran the ADP test and processed 3 corrective distributions By March 15.  The plan auditor discovered in August, there was incorrect compensation on the census file.  The 3 with the refunds ended up with higher wages.  Of course then it meant the the issued refunds were too high. Approximate example: correct refund should have been $5500 but $7500issued.  Two of the 3 are over 59 1/2 and so their excess can be considered in-service under the terms of the plan.  

But then there is the younger HCE.  Do you believe this must be corrected?  We could have the participant return funds and have the record keeper change the 1099-R that will come out in January if that's even possible.  I'd rather avoid that. 

Thoughts - thank you. 

Tom

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