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Posted

Can a client remove Roth from a safe harbor plan mid-year?  I don't see any rules precluding this.  Only 30 days notice as Annual Contribution notice is affected.  Your thoughts?

Posted

cpc0506, I agree it does not seem to be prohibited by Notice 2016-16, and therefore would appear to be permitted. But I believe that the ability to do Roth is required to be included in the annual safe harbor notice, so you would need to follow the notice provisions of Notice 2016-16 for changes that affect annual notice.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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