coleboy Posted March 30, 2018 Posted March 30, 2018 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?
Belgarath Posted March 30, 2018 Posted March 30, 2018 Employer must contribute full missed match, plus earnings on that match.
coleboy Posted March 30, 2018 Author Posted March 30, 2018 So, he will receive a match on the deferrals that he never made? Does it go in as a match? Or as a QNEC?
401_noob Posted March 30, 2018 Posted March 30, 2018 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
Belgarath Posted March 30, 2018 Posted March 30, 2018 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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