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Early Correction of Elective Deferrals Less Costly Under New EPCRS (PDF)
BuckLink to more items from this source
[Guidance Overview]
Apr. 8, 2015
"The IRS recognizes that a QNEC for the missed deferral opportunity is a windfall for employees but takes the position that it's justified as a penalty for plan sponsors who do not promptly address administrative errors.... Although the 45 day notice requirement could limit availability for breaches identified and partially corrected in prior periods, it should be recalled that the EPCRS correction principles generally call for a correction that is 'reasonable and appropriate for the failure.' ... So missing the notice requirement may prevent using the option from being a deemed reasonable safe-harbor, but won't necessarily mean that it is not reasonable and appropriate for the failure."

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