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Posted

Does it say anywhere that the comp limit is the FIRST $345,000 earned? (for 2024)

My doc says "Compensation in excess of $200,000 [as indexed] shall be disregarded for all purposes other than for purposes of Elective deferral."

Does that mean someone who earns $700,000 a year, but doesn't start deferring until the second half of the year will get no match?  Doesn't make sense.  But plan sponsor and advisor want something in writing.

 

QKA, QPA, CPC, ERPA

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

Posted

Reg 1.401(a)(17)-1(a)(1) says in part "Section 401(a)(17) provides an annual compensation limit for each employee under a qualified plan."  There is no time element associated to the limit.

The IRS does note that a plan document could specify that deferrals (and related match) could stop when a participant's compensation first reaches the compensation limit.  See https://www.irs.gov/retirement-plans/401k-plans-deferrals-and-matching-when-compensation-exceeds-the-annual-limit

Taken together, if the plan document doesn't explicitly require stopping when YTD pay reaches the compensation limit, then it is okay not to stop.

The plan sponsor and advisor need to show you where the plan document says to stop when YTD compensation first reaches the limit.

Posted

I am rather dismayed that this question keeps popping up. However, it is good to be reminded that the plan document controls, though I often wonder whether the sponsor is making a conscious choice to serve some policy reason or it is simply a default in the design by the document provider.

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