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Posted

Employee's 10% deferral election was not implemented for over a year.  SH nonelective plan.  I don't believe SH plans can use the reduction from 50% to 25% for the QNEC, can they?  The employee should get a 5% QNEC for the deferral, plus the 3% SHNEC, plus earnings, right?

Posted

No - same rules apply - can utilize 25% QNEC on missed deferral as long as notice provided within 45 days of starting correct deferrals and corrected within the SCP window.  The 3% SHNEC plus earnings is required

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