"IRS' Retirement News for Employers explains that when a notice is not provided to a participant timely, there may be differing results. Some participants may have been deferring all along, and the fact that the notice was not provided may have no impact on their saving behavior. Others may actually fail to defer because there was no notice.... When safe harbor notices are not distributed or are not distributed timely, the plan administrator must determine if the error resulted in an employee not deferring, in which case the error is corrected in the same manner as if the employee was excluded from participation."

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