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Admin220 created a topic in Correction of Plan Defects
"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
"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
"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
"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
"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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