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Posted

A client missed starting an employee's deferrals and discovered the error less than 3 months later. The plan has a match. I understand that, being 3 months or less, no QNEC is needed but what about the match. Does anything need to be done about the missed match?

Posted

He will receive a match on the deferrals he never made.

https://www.asppa.org/News/Article/ArticleID/4784/IRS-Highlights-New-Methods-for-Correcting-Elective-Deferral-Errors 

They also need to issue a notice to the participant no later than 45 days after correct deferrals begin in order to be eligible for this correction method. Rev. Proc. 2015-28 describes the notice requirements.

 

New Methods for Correcting Elective Deferral Errors.pdf - Adobe Acrobat.pdf

Posted

I don't have time to look it up now, but I think if it is a safe harbor matching contribution, it is a QNEC, otherwise, it is just an employer nonelective. But don't trust my memory - I don't!

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