Client has integrated final pay plan that they plan to freeze at end of current year. However, they would also like to credit all active participants as of that time with an additional year of service. So if someone has 20.667 years of credited service (they use elapsed time), they would be bumped up to 21.667. Plan satisfies coverage and integrated formula is 401(l) compliant (1% /.5% at $4800). Does giving everyone an additional YOS mess up my integration and force me to general test, or am I still safe harbor because everyone gets it? Any other potential traps for concern?

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A client missed starting an employee's deferrals and discovered the error less than 3 months later. The plan has a match. I understand that, being 3 months or less, no QNEC is needed but what about the match. Does anything need to be done about the missed match?

Just ran across an interesting situation. Employer missed withholding a deferral here and there on several employees. They understand they have to make full missed match plus earnings. However, their correction on the missed deferral piece has been as follows: They have simply withheld the missed deferral at a later date (anywhere from next paycheck to several months later). I think in "real life" this is acceptable IF the employee does a separate written election to permit it. However, I don't think it is acceptable to do it 6 months later without a written election. Don't know if they have even gotten VERBAL approval, but apparently no one has ever complained. How do y'all see this situation handled (if you ever do see this correction method) when the correction falls outside the "normal" SCP corrections? Just curious.

Good Morning - Can someone please walk me through how to properly correct the following situation: Small plan - less than 100 participants determined they were incorrectly reporting loan failures. The loan would default due to the participant separating from service and the sponsor would offset the loan once there was a distribution of the account. Sometimes it was in the current year and sometimes it was 5 years down the road. There are several participants who terminated employment several years ago and they are trying to properly tax report on these loans. My understanding is you can self-correct on those loans that are within the three-year statute of limitations by reporting on a 1099-R in the year of the failure. Those that are beyond the statute of limitations would need to go under VCP to request 1099-R reporting in the current tax year (those within the statute of limitations could also be reported in the current year as well with IRS approval). Is this correct? Now for the real question - I know one can self correct by the end of the second plan year on these loans failures whether an significant or insignificant failure. My understanding is a determination needs to be made outside this two year window as to whether this is significant or insignificant, correct? I think I am unsure because the loan corrections under EPCRS are not intuitive to me (but what is).