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Posted

Let's say it is June and we see that we missed a deferral election for 4 months.  
The missed deferral was $2,000.  The correction will be 25% or $500.

Will the $500 QNEC be counted in his 402(g) limit for 2018?

 

Posted

It doesn't count for 402(g) purposes, but counts toward 415.  Make sure to send out applicable notice to affected participant to take advantage of the 25% QNEC.   

Posted

Rev. Proc. 2015-28 adjusted the calculation of QNEC from 50% to 25% in certain instances.  However, it doesn't seem the new rev. proc. changed the other requirements of EPCRS contained in Rev. Proc. 2013-12 where Appendix B, Section 2.02(1)(a)(ii)(B)(1) indicates the missed deferral is reduced by elective deferrals actually made would exceed the 402(g) limit.  However, any missed match, with the same 402(g) limit assessment, would need to be funded if match was reduced.  For example, pay period match was provided and participant deferred a higher % to account for the missed 4 months where the 4 months would have provided for higher match.  If yearend match, and match was fully funded regardless, no match would seem to be required.

ERPA

Posted
22 hours ago, CJ Allen said:

Rev. Proc. 2015-28 adjusted the calculation of QNEC from 50% to 25% in certain instances.  However, it doesn't seem the new rev. proc. changed the other requirements of EPCRS contained in Rev. Proc. 2013-12 where Appendix B, Section 2.02(1)(a)(ii)(B)(1) indicates the missed deferral is reduced by elective deferrals actually made would exceed the 402(g) limit.  However, any missed match, with the same 402(g) limit assessment, would need to be funded if match was reduced.  For example, pay period match was provided and participant deferred a higher % to account for the missed 4 months where the 4 months would have provided for higher match.  If yearend match, and match was fully funded regardless, no match would seem to be required.

This is from the same section of Rev. Proc. 2016-51, the current version:

The missed deferral for the portion of the plan year during which the employee was improperly excluded from being eligible to make elective deferrals is reduced to the extent that (i) the sum of the missed deferral (as determined in the preceding two sentences of this paragraph) and any elective deferrals actually made by the employee for that year would exceed (ii) the maximum elective deferrals permitted under the plan for the employee for that plan year (including the § 402(g) limit).

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