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Retirement Plan Correction Solution Meltdown: Correcting Automatic Enrollment Failures
Ferenczy Benefits Law Center Link to more items from this source
[Guidance Overview]
Aug. 25, 2021

"Typically, a company must correct a failure to timely implement a deferral election by making a qualified nonelective contribution ('QNEC') in relation to an affected participant's missed deferral. The QNEC must equal the participant's 'Missed Deferral Opportunity' ('MDO'), which is defined as 50% of the amount the participant elected to defer. However, if certain criteria are met, the QNEC may be reduced to 25% of the MDO. But, for plans with [automatic enrollment] provisions, there is a special deal: the employer may avoid making a QNEC at all if certain conditions are met."

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