austin3515 Posted July 17, 2019 Posted July 17, 2019 Have a situation where a missed deferral opportunity was corrected in such a way that very closely resembles the EPCRS pre-approved correction. They calculated the "missed match" in such a way that some participants will end up wth slightly more than a 4% safe harbor match. The specifics are not relevant to my question so I'll forego a detailed explanation. The question is EPCRS Section 6.02 (Correction Principals) says "(a) The correction method should, to the extent possible, resemble one already provided for in the Code, regulations, or other guidance of general applicability." The correction method they used is resemble, and does resemble very closely what EPCRS says (including notice requireements, making up for missed match etc). It is just that the method of calculating the missed match provides them with a little bit extra than the EPCRS methodologies would have. Is this still a suitable correction under EPCRS SCP? Or is their essentially a "Do it this way or it's or you don't get any reliance"? We are capping anyone over $275K (in 2018) at the maximum match based on the normal formula. So this new approach will not allow anyone to get more than the match based on max comp. For whatever that is worth. Austin Powers, CPA, QPA, ERPA
RatherBeGolfing Posted July 18, 2019 Posted July 18, 2019 I don't see why it wouldn't be suitable. 6.02 also says the correction method has to be reasonable and appropriate, that you could have more than one reasonable method, and that the methods in the appendix are deemed reasonable. As long as you consider all the principles for determining whether a method is reasonable (6.02(2)(a)-(e)) you should be fine.
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