| FAQ 402: ADP--ATM not being calculated on those HCEs with catchup, but is on other HCEs |
Here is more detail to my ATM question.
50% up to 6% of deferred compensation.
Participants earning comp of 210,000 and deferring 14,000 (6.67%) receive a match of 6,300 (210,000 x 6% x 50%).
If a failed ADP test results in a 401K refund of 1,947.52, the adjusted deferral is 12,052.48 (14,000 - 1,947.52) and the adjusted deferral percentage is 5.74%. Consequently, the match on this adjusted deferral is 6,026.24 (210,000 x 5.74% x 50%). The ATM refund is 273.76 (6,300 - 6,026.24).
The ATM refund is being calculated for the only HCE earning 210,000 who has not made catchup contributions. However, the ATM refund is not being applied to the 3 other HCES who earn 210,000 and deferred 18,000 (14,000 + 4,000). Note that these 3 HCES must also receive a 401K refund of 1,947.52. What am I miscoding?
The difference is, as you figured out, the catchup amount. The catchup actually remains in the plan and so there is no ATM calculated on that amount. The default setup assumes that catchups are matched per the document. If they are not, then you can calculate the ATM on this catchup by checking the "Calculate ATM on Catchup Contrib" option when setting up the ADP test.