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ErikandDeena
If a participant is in a 403(B) and a 403(B) that is an ORP plan that requires a mandatory Employee contribution, are they limited to $12,000 (considering they are age 50) between the two plans? Or can they max in each?
Yanikoski
The $12,000 limit is a limit on elective deferrals. Since the ORP contributions are based on a one-time election and thereafter are mandatory, the ORP amounts are NOT elective deferrals and are not subject to the $12,000 limit. So, normally, an employee can contribute $11,000 (or $12,000, if age 50+ -- or up to $14,000 or $15,000 if eligible for the $3000 catchup) IN ADDITION to the ORP contributions. Keep in mind, however, that the total of ORP plus voluntary contributions may not exceed the Section 415 limits of $40,000/$41,000 or 100% of includible compensation (which normally equals gross compensation minus ORP contributions).
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