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May 19, 2026

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HRagain created a topic in 401(k) Plans

401(k) Correction

"Participant became eligible to participate on 11/1/25. Participant chose 6% Pretax Deferral that came with 4.5% Employer Match (with a 5 year cliff vesting schedule) along with receiving a 3% Safe Harbor contribution each pay period (there were 4 left in 2025). Each pay period had the same amount of Plan Eligible Compensation (basically gross salary without bonus or GTL imputed income) and the same amount of deferrals and contributions. When compliance tests were run, somehow the recordkeeper forfeited a small amount of Employer Match and Safe Harbor for 2 employees (the other was eligible on 3/1).... I found that both withdrawals were forfeited amounts plus associated earnings ... And lo and behold the eligible pay was incorrect.... In the end, on the 5/15/26 payroll submission, that dept added those two amounts in with current SH and ERM (such that now payroll doesn't match the recordkeeper for 2026 and these two will be overstated in the 2026 compliance records or at least won't match between payroll and the recordkeeper). And I didn't get the miniscule interest back nor interest from 4/13 to 5/15....

"[My] question is did something change on how corrections are completed? Is this now how 'corrections' are done? Would it not be 'cleaner' to have the recordkeeper reverse the two participant ERM/SH forfeitures and put the earnings back at least for that time period? Because it still shows as a forfeited withdrawal on 4/13 and an increased contribution for 5/15.... Am I wrong to think [1] it should have been communicated when approved to withdraw -- wouldn't most internal plan administrators give the employees a heads up and [2] I should have gotten the original earnings back along with another month's earnings?"

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BG5150 created a topic in 401(k) Plans

Safe Harbor Dual Eligibility and Top Heavy Question

"Plan has dual eligibility for deferrals and SH Match. I understand that removes the Top Heavy 'pass' plans often get. The Plan has like 10 participants, everyone has been there several years. Plan is 80% TH. Are they subject to the TH minimum every year? Or is it just for years where there is someone new and they are not eligible for the SH Match? (We have since amended the Plan to have the same eligibility for SH as deferrals.)"

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