In practice, does anyone have a de minimis policy or policies pertaining to returning excess contributions, excess aggregate contributions, excess deferrals, or other items? Or does everyone distribute the excess, even if the excess is 1 cent?

John,

Were you able to get any responses to your thread? Can you tell me if you did implement a de minimis policy?

I have a failed 415 test ($.06) and it seems silly to have to reallocate such a nominal amount, pursuant to the terms of the Plan, but maybe that's what I need to do.

I have talked to other administrators who have a policy of treating any amount under $1 as forfeitures and cutting a check for any amount that is $1 or above, but I have not talked to anyone that was willing to go "on record" as having that policy.

I can see logic in "forfeiting" distribution amounts <$1, but do you think leaving an excess annual addition in a Participant's account of <$1 jeapordizes a Plan because it truly doesn't satisfy 415?