FAQ 420: ADP--Borrow from the ACP to the ADP

Problem:

My plan is failing the ADP and passing the ACP. I want to borrow from the ACP match money to help my ADP percentage. Please let me know how to set this up.


Solution:

ASC does not borrow in that direction. We borrow from ADP to ACP only. Borrowing from the ACP to the ADP requires that you actually move match monies to a separate account and maintain them like deferrals (e.g. 100% vest, distribution restrictions). It is not just "playing with numbers" like it is when you borrow from the ADP to the ACP.

If the Match is 100% vested, you can include (Sources for ADP Test) the Match source to be test with the Salary Deferral sources in the ADP test.