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Posted

Would a QACA match of 100% of the first 6% be classified as safe harbor to avoid ADP/ACP testing on an automatic enrollment/increase plan.  I know safe harbor formulas can't match on anything over 6%, but I generally only see QACA matches quoted as one of these 3 options:

  • Match 100% of first 1% and 50% of next 5%
  • Match 100% of first 3.5%
  • 3% non-elective for everyone (not a match)

Some sources I've found say 3.5% is the max possible QACA match, which seems like a fairly low limit for some employers that want to do more.

Posted

1.401(k)-3(k)(2) says that when applying 1.401(k)-3(c) [the SH Match] to a QACA, the basic safe harbor match formula is replaced with the QACA match formula.  The basic SH match is the minimum that must be provided to be safe harbor.  1.401(k)-3(c)(1) includes the option to have an enhanced match [1.401(k)-3(c)(3)]. So yes, you can provide a larger match in a QACA than the minimum required.  If you are using a pre-approved document, it should have an option to use an enhanced QACA match.  Our volume submitter document allows it. 

 

Posted

Kevin, thanks for your comments on this issue.  I'm glad to hear this flexibility is available for employers that want to be more generous.

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