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


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.


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.