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Posted

For a 7/1/24 - 6/30/25 plan year, would participants that are age 60-63 at 12/31/25 be able to make the additional catch-up (if the plan wanted to allow)?  Or is it effective for plan years starting after 12/31/24? If a plan fails 6/30/25 PYE ADP testing and someone age 61 has all C/U available, would 11,250 or 7,500 be reclassed for this PY?

402(g) limit is tied to the individual and calendar year.  Everything I'm seeing about special catch-up references taxable year.  But perhaps 401(a)(30) / plan's responsibility to monitor the limit changes effective date of this?

Thanks in advance!

Posted

The recharterization on the 6/30/2025 test uses calendar 2025 catch-up is my understanding so if the plan allows enhanced catch-up I believe you can recharterize that as part of the correction if the participant is enhanced CU eligible for 2025. 

Posted

Quick caution, 402g limit and 414v catch-up limits are based on the individual's taxable year, not the plan year.  I have never encountered a participant with a taxable year other than 12/31, but it is possible.  Check out the linked thread for more insight.

 

 

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