"Company had a bonus run mid-March. They told everyone mid February that the employees would have to go into the recordkeeper to change their deferral rate for the bonus if they wanted it changed, then go and switch it back after the run. This is a 360 integration and the recordkeeper sends a file feed to the payroll company with deferral changes on a pre-determined schedule. Turns out, the payroll company did not get the change file until several hours after the bonus was run. There were some 200 people who changed their rates and nearly all lowered or eliminated the deferral for the bonus. So now we have excess allocations. Simple enough fix: distribute the excess amounts (with earnings) to the participant. However, some people had very large amounts deferred. How does the company/payroll take into consideration that amount when looking at the 402(g) limit later in the year. many of these people max out each year. For example, Laura was deferring $2,000/month, intending on maxing out in December. Her bonus run had a deferral of $15,000 (yes, deferral was $15,000, not the bonus!). So, at the moment her YTD deferrals are $19,000 (and will be $21k on Friday). If we refund her the $15k, it brings her PLAN contributions back to $4-6,000. But in the PAYROLL system she will still be at $19-21,000. Do they just go in and manually change the YTD 401(k)? I don't want them to stop her after May and having true deposits of only $10,000."

"An accountant asked whether DB contributions in an owners-only DB plan are deductible in New Jersey. Any reason why they should not be?"

"A 401k plan has a 4 year graded vesting for all employees. The question is can they have a different more generous schedule for a certain job class, for example nurses. There are HCE's and NHCE's in the nurse job class. Will this require BRF testing?"