Missed Auto-Enrollment Contributions

Good morning everyone.  We have a client who inadvertently failed to start auto-enrollment contributions for several employees.  I just want to make sure what the correction is for this type of mistake?  Do they catchup the missed contributions via the next payroll and pay them interest for the missed contributions? 

For the interest, what's the best way to calculate?

Thank you in advance

Depends upon the timing. Take a look at Rev. Proc. 2021-30, Appendix A (.05)(8) - that'll give you the information you need.

8 minutes ago, Belgarath said:

Depends upon the timing. Take a look at Rev. Proc. 2021-30, Appendix A (.05)(8) - that'll give you the information you need.

Thank you!  I just want to make sure I'm reading this correctly.  All of the missed deferrals are from August and later so it's all current and there's no current match.  That means they just have to start the contributions ASAP, correct?

Well - depends upon what you mean by "there's no current match." Suppose at the end of the year, a match is made based on all deferrals for the plan year. (I'm assuming from your comment that they don't match per payroll.) In that case, they would be entitled to the match on the missed deferrals. 

2 minutes ago, Belgarath said:

Well - depends upon what you mean by "there's no current match." Suppose at the end of the year, a match is made based on all deferrals for the plan year. (I'm assuming from your comment that they don't match per payroll.) In that case, they would be entitled to the match on the missed deferrals. 

There's a discretionary match in the Plan, but it isn't going to be used for this year (1st year of the Plan).

My bigger concern was that we needed to go back and catchup the missed deferrals.  But since there isn't a match, that doesn't appear to be the case.

Yup, you should be good, assuming you otherwise satisfy the requirements of that section of the Rev. Proc - (Notice requirement, timing of starting correct deferrals IF the employee notified the employer of the error).