Chippy Posted February 23, 2018 Posted February 23, 2018 Plan has immediate entry for deferrals. A participant was hired on 9/17/2013. (2/28 PYE). Switched to 12/31 pye at 12/31/2014. 2% initial deferral, no increase. They have never included this employee, so have to make up for 2/28/2014, 12/31/2014, 12/31/2015, 12/31/2016, 12/31/2017 and January and February 2018. Is the missed Deferral, 2% or do I use the ADP and give them 50% based on that? Never had this with automatic enrollment. Thanks
401king Posted February 23, 2018 Posted February 23, 2018 Was the auto-enrollment notice provided to the participant? I.e. were they given an opportunity to enroll? R. Alexander
Chippy Posted February 23, 2018 Author Posted February 23, 2018 No. There is a new person at the company and she sent me the 12/31/2017 census and included this participant. This is the 3rd contact for the plan in 5 years. When I asked why she was never on the census prior, she had no Idea and couldn't find a reason why. She is part time, but had over 1,000 hours in each plan year. She also did not receive a profit sharing contribution in each of the years.
401king Posted February 23, 2018 Posted February 23, 2018 Given that no notice was provided to the employee, I lean toward using the higher of the two (50% of ADP vs. 50% of missed ACR). Plus earnings. R. Alexander
Chippy Posted February 23, 2018 Author Posted February 23, 2018 I was just informed that this person's last day was on Tuesday. They still have to give this participant the missed contributions? correct?
401king Posted February 26, 2018 Posted February 26, 2018 I do not believe their terminating employment should preclude them from receiving the corrective contributions for prior years. K2retire 1 R. Alexander
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