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Posted

Issue 1.  Ineligible participation:  Plan sponsor allowed an ineligible employee to participate in the plan too early during 2017.  For whatever reason, the client does not want to retro-actively amend to correct this specific person's participation.   This plan processed a refund of the deferral and forfeiture of the affected employer match today, 10/9.  (Yes, today.  Don't get me started on that story.)

Issue 2. ADP-ACP refunds:  The plan is also tested; failed ADP-ACP (of course) and corrective refunds are being processed.  Again, it is October.  Obviously, well past 3/15.

12/31/2017-ending plan year...  Both issues occurred in the same tax year and being corrected in subsequent (current) year.  I am either rusty, brain-mushy, or both...  But, I cannot seem to recall and need a solid favor here, my friends.  Please provide a quick sanity check: Can we report both of these bad boys on one 5330...  Yay?  Nay? 

For any replies, please accept advanced thanks!

Posted

No.  Each defect must be reported separately.  

The Form 5330 itself says "You can only complete one section of Part I for each Form 530 filed."

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