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Posted

Background:

Non-Electing 403(b)(9) Church Plan 
2026 Limits apply

Participant age 50
Includible Compensation = $80,000
Deferrals = $8,000
Employer Contributions = $72,000

Question:
I will admit this seems so basic, but for some reason I am feeling perplexed today (sigh). Perhaps my understanding has been wrong all along, but I was originally under the impression that one did not have catch-up contributions until he/she exceeded the 402(g) limit.

Is there any instance where the employee deferrals in this scenario would be considered as age-50 catch-up contributions, avoiding an excess contribution scenario? Does the timing/order of the contributions matter? (For example, if first the employer contributions were made and maxed out the 415(c) limit, could deferrals made after that count as catch-up contributions?)

I read through section 414v and became confused by it stating [paraphrased], catch contributions are deferrals made that exceed ANY of the applicable limits, of which include limit on elective deferrals OR annual additions. In the scenario above, he exceeded the 415(c) limit with employer contributions. Does that point alone justify future deferrals in that year as catch-up?

"With respect to an applicable employer plan, catch-up contributions are elective deferrals made by a catch-up eligible participant that exceed any of the applicable limits set forth in paragraph (b) of this section ... 
paragraph (b):

(b) Elective deferrals that exceed an applicable limit—(1) Applicable limits. An applicable limit for purposes of determining catch-up contributions for a catch-up eligible participant is any of the following:

(i) Statutory limit. A statutory limit is a limit on elective deferrals or annual additions permitted to be made (without regard to section 414(v) and this section) with respect to an employee for a year provided in section 401(a)(30), 402(h), 403(b), 408, 415(c), or 457(b)(2) (without regard to section 457(b)(3)), as applicable.

TIA

 

Posted
25 minutes ago, KaJay said:

In the scenario above, he exceeded the 415(c) limit with employer contributions. Does that point alone justify future deferrals in that year as catch-up?

Yes, if someone gets employer contributions in a year that are equal to their 415(c) limit of the lesser of 100% of pay or $72,000, then any and all deferrals would be deemed catch-up contributions.

In your example, the person could actually have had compensation of $72,000, an employer contribution of $72,000, and $8,000 in catch-up contributions.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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