I need the following paragraph interpreted for me. It's safe harbor correction methods for employee elective deferral failures.... page 78. For the "No QNEC" needed.

(i) Correct deferrals begin no later than the earlier of the first payment of compensation made on or after the last day of the three-month period that begins when the failure first occurred for the affected eligible employee or, if the Plan Sponsor was notified of the failure by the affected eligible employee, the first payment of compensation made on or after the end of the month after the month of notification; Participant notified Employer that contributions weren't right 3/27/2019. The deferral failure started with the first payroll of 2019, 1/11/2019. There was an error by the Employer.

There is two pieces to the above paragraph. The EARLIER....?

First piece throws me off on really what it means. Does this mean that if the Employer noticed the error, they have until first payment in April 2019 to get the correct deferrals started?

The second piece I follow, the Employer can get the right percentages coded, send the notice, make sure the appropriate match is made and move on. The fix needs to be done in April 2019. It appears that the EARLIER date of correction needs to be implemented by first pay of April 2019. Am I interpreting correctly?

We administer a SH 401(k) plan for a local dental practice. The dentist was the sole trustee of the plan and did all the payroll information and submission of funds weekly as his employees were paid. Unfortunately he recently died. Now the office staff is trying to figure out how to submit the money that was withheld in February on behalf of the employees because it has not been done and now a bigger problem has arisen -- no deductions were taken in March for any employees. How can this be resolved? There is a current dentist that is in the process of trying to acquire the assets of the practice. Whew -- a mess for sure.

Under the revised rules for amending a safe harbor plan midyear, the plan may not reduce the number of employees eligible to receive safe harbor contributions. What if the midyear amendment were to exclude only the owners from receiving the safe harbor match? Would that be possible? If so, I'm assuming this would need to be a prospective amendment (not effective as of 1/1/2019). Owners have not deferred yet in 2019 anyway.