It's a 401k Safe Harbor Match
provisions read that match is to be made on a payroll by payroll basis
Client has HC participants that receive varrying amounts of comp, sometimes large, sometime not at all
Client also has participants that have instructed not to defer on bonuses
Needless to say, the match %'s are all over the place.
We have highly comp's that have well over the $225,000 in comp but are not receiving the full $9000 because the calculation is done on a payroll basis. If we true him up, shouldn't we true everyone else up.
Also, am I correct in instructing the client to defer and match on bonus utilizing provisions of the document, not necessarily what the participant wants to do.

I am not aware of a way to selectively apply true-up provisions.



Documents rule, participants drool!

It is possible for the document to use a definition of comp. that includes bonuses and the participants still elect not to defer from bonuses by changing their deferral election. It would depend on the frequency of changes that are permitted in the document.