We had someone come to us that currently has a SARSEP - they are looking to transfer reps - however they think they may have over contributed for the owners in 2003.
1. I know you take the average NHCE deferral, do you take the AVERAGE highly comp deferral - or individually. For example...
John Doe - Owner - Contributed 5.5%
Jane Doe - Owner - Contributed 6.5%
The NHCE average deferral was 5% X 125% = 6.25%.
In the above situation would John Doe be fine and Jane Doe have to be corrected - or could you take the average to make 6% and they both pass?
2. Let's say they fail either way - what are the correction methods and/or penalties?
Before we do anything with this, we want to make sure that all is correct with the world! Thanks for the insight!