TN CPA Posted January 30, 2020 Posted January 30, 2020 Our client maintains a safe-harbor matching 401k plan. A long-time employee (HCE) transitioned to a part-time role and is now working less than 1,000 hours per year. (The eligibility requirement listed in the plan document.) Is this employee still eligible to make 401k deferrals and receive the safe-harbor match or excluded because he no longer meets the eligibility requirements? The document does not address this situation - only that the eligibility requirements are Age 21 and 1000 hours of service. Thank you for your feedback!
Larry Starr Posted January 30, 2020 Posted January 30, 2020 22 minutes ago, TN CPA said: Our client maintains a safe-harbor matching 401k plan. A long-time employee (HCE) transitioned to a part-time role and is now working less than 1,000 hours per year. (The eligibility requirement listed in the plan document.) Is this employee still eligible to make 401k deferrals and receive the safe-harbor match or excluded because he no longer meets the eligibility requirements? The document does not address this situation - only that the eligibility requirements are Age 21 and 1000 hours of service. Thank you for your feedback! Barring any (unusual) language, once a participant always a participant. He can continue to defer. Luke Bailey 1 Lawrence C. Starr, FLMI, CLU, CEBS, CPC, ChFC, EA, ATA, QPFC President Qualified Plan Consultants, Inc. 46 Daggett Drive West Springfield, MA 01089 413-736-2066 larrystarr@qpc-inc.com
Bill Presson Posted January 30, 2020 Posted January 30, 2020 1 hour ago, Larry Starr said: Barring any (unusual) language, once a participant always a participant. He can continue to defer. And receive the safe harbor matching because there can't be any hours requirement once the eligibility is met. I know that was implied. Luke Bailey 1 William C. Presson, ERPA, QPA, QKA bill.presson@gmail.com C 205.994.4070
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