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September 9, 2025

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Admin220 created a topic in Correction of Plan Defects

ADP Failure Correction Adjustments

"We processed the ADP failure in March 2025 -- client just provided new census and now ADP failure amount is significantly less after re-test. Trying to find the proper way to correct, not seeing anything specific on my situation."

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MGOAdmin created a topic in 401(k) Plans

SIMPLE Roth Rollover

"Now that SIMPLE plans can allow Roth, can you roll SIMPLE Roth into a 401k Roth? I know regular Roth IRAs cannot be rolled into a 401k plan but couldn't find any rules on SIMPLE plans."
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401k Conundrums created a topic in 401(k) Plans

Late Deposits (Small Plan Vs Large Plan After New Participant Counting Methodology)

"Does the 'small' plan status also extend to deposit timing rules with the new 2023 DOL change to the participant counting methodology? I have a client with 1,000 plus eligible plan participants but less than one hundred participants with account balances, so are they a small plan with regard to the deposit timing rules?"

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Lucky32 created a topic in Retirement Plans in General

Retroactively Amend Plan to Make Allocation Requirement More Generous?

"A small top-heavy calendar-year profit sharing plan has a 1,000 hour requirement for allocations. It has a new comp allocation method, with each participant as their own rate group. There's an NHCE participant who went from full-time in 2023 to <500 hours in 2024 and worked through the end of the year, so she will get the TH min and I believe also the gateway contribution (as the HCEs are getting hefty allocations), but does not qualify for a PS allocation. The new comp testing would work out a lot better if she did get a PS allocation -- is it permissible to retroactively amend the plan for 2024 now to eliminate the hours requirement so that she can get a 2024 PS allocation? No HCEs would benefit from this change."

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FishOn created a topic in 401(k) Plans

SECURE 2.0 Act Section 603 Mandatory Roth Catch Up - ADP Testing

"For traditional tested plans, an ADP test failure can be corrected by recharacterizing excess contributions as catch-up contributions, provided the HCE has not yet reached their maximum catch-up contribution limit for the year. I have not been able to find much, if anything, on the impact of testing failures where recharacterizing excess contributions as catch-up contributions will cause a the catch-up to be recharacterized as Roth for those that are HCEs who are also High Income Earners. If the HCE (is also HIE) made only pre-tax contributions, will recharacterizing excess contributions to catch-up mean that we have to do a Roth Transfer for the catch-up portion?"

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