"Compensation includes bonuses. Participant A made an affirmative elective to defer; Participant B was auto enrolled. There were bonus payments issued in 2024 and deferrals were not withheld. How to correct -- Does the 9 month rule apply so no QNEC is required? The 9 month rule would apply if the initial elections were not timely processed (assuming deferral elections must be properly implemented consistently from April 1st -- December 31st). The question is does the 9 month rule apply regarding missed deferrals subsequent to enrollment. Deferrals properly calculated. When the bonus was paid no deferral was calculated. We have differing opinions: One opinion is the 9 month rule applies even though these are deferrals after the initial elections were processed; The other opinion is the 9 month rules does not apply since these are missed deferrals subsequent to enrollment and are subject to a QNEC."

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