"In January, ensure new salary deferral elections for the current year are implemented timely and correctly. In March and April, companies with annual incentive payments based on the calendar year should ensure that annual bonus deferral elections are properly applied and new bonus deferral elections are implemented.... In January, identify any payments that are required to be made in the current year based on a distribution event in a prior year ... Corrections of 409A failures are allowed up to the end of the second year after the year of the failure."  MORE >>