QUOTE (Sieve @ Jul 6 2009, 04:32 PM)

I don't know what "much later" means, but there is a de minimus rule where a correction is permitted if the employee can increase deferrals for the last 9 months of the year. In that case, corrective contributions are not necessary. (Rev. Proc 2008-50, App. B, Section 2.02(1)(a)(ii)(F).)
They were excluded until this week! I wasn't sure how to apply that example since we're not dealing with a 12-month period as they should have entered the plan on March 1, not January 1. By allowing them to defer now we would be able to offer only 6-1/2 months to defer. Would 6-1/2 months of deferrals be satisfactory if the plan allows deferrals of 100% of comp? Who knows?!