jaemmons
Jun 21 2004, 03:20 PM
Plan failed 12/31/2002 test and was using prior year nhce %'s. Client wishes to correct using the QNEC method, under the Self-Correction program under EPCRS.
I need some clarification as to who is considered an "eligible non-highly compensated employee" for the QNEC. Can we use the plan's allocationi formula, which is currently a "bottom-up" approach or do we need to give the corrective QNEC to all employees who were eligible to defer in 2002, regardless of the plan's eligibility provisions for QNEC's.?.
Tom Poje
Jun 22 2004, 06:29 AM
I assume you mean the one- to -one correction method under SCP.
Appendix B 2.01(b)(iv)(B)(1) states that the contribution is allocated either as the same percentage of comp or the same dollar amount to each employee.
this would seem to rule out a bottom up QNEC
qualified plan
Jul 22 2004, 05:09 PM
Wouldn't the QNEC method set forth under Appendix B 2.01(a) also work?
philc
Jul 23 2004, 10:20 AM
If the plan defines the QNEC method as bottoms up, but the employer wants to correct under EPCRS using the one to one method (comp/comp), does the plan have to be amended from the bottoms up to one to one?
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