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What are the options for adding a student loan match now in 2025 to a non-safe harbor calendar year plan? The plan has a payroll period based match. Would the student loan match have to start mid year for example 5/1/25 in order to be payroll based, even though it can be funded annually after 2025. I am thinking if they want to make the student loan match retroactive to 1/1/25 they would need to amend the match formula for all participants - regular deferrals and student loan repayments - to be an annual match and look at compensation and deferrals retro to 1/1/25. IRS Notice 2024-63 indicates the match has to be at the same rate. Thoughts?

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