Explaining True-Up Matches

DC plan sponsors may want to offer a true-up match to help participants reach their retirement savings goals.

Plan sponsors, advisers and providers are always recommending defined contribution (DC) plan participants defer enough of their salaries into the plan to receive the full employer match contribution.

In order to make sure participants are maximizing their retirement savings, plan sponsors may offer a true-up match.

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What is a true-up match? This type of contribution allows employers or plan sponsors to fund the difference in match contributions for participants who may reach the maximum statutory deferral amount prior to the end of the year or for participants who did not contribute enough for part of the year to receive the full match.

A true-up match is contributed at year-end or one to two months following the new year, largely because plan sponsors must review all funded contributions completed throughout the 12 months, according to Michael Knowling, vice president of Client Relations and Business Development at Prudential.

“It allows [employees] to not leave free money on the table,” Knowling says. “It allows them to maximize their employer contribution or employer matching contribution.”

Knowling says it’s an extra benefit for workers, and it helps plan sponsors by helping participants maximize DC plan savings.

NEXT: The true-up process

If a plan document includes a provision for a true-up match, who manages the true-up can go two ways, says Knowling: either the recordkeeper can perform the calculation or it can be performed in-house by the plan sponsor.

Plan documents often have wording such as, “the employer will match 50% of salary deferrals up to 6% of the employee’s compensation for the plan year.”   

“Employers are going back and kind of doing the match on [participants] behalf and background, saying, ‘How much do they make, what’s the minimum match they should have received and where’s the gap?’ and they’re applying the contribution on their behalf,” says Meghan Murphy, director at Fidelity Investments.

For a highly compensated employee, Knowling gives this example: “Let’s say an employee is contributing 15% of salary, or $1,500 a month, to the plan, that will allow them to reach the statutory contribution limit by year-end. Let’s just say in that scenario, the company has a matching contribution where they match 50% of the first 10% that’s contributed, in that situation the employee would get the full company match with no action required. On the other hand, let’s say that the employee has a contribution each month of $3000 instead of $1500. This participant is actually going to hit the statutory limit, probably six months into the year. At a match of 50% on the first 10% they contributed, the participant will receive less match than if he spread his contributions out over the year. A true-up contribution allows the employer to contribute the difference into his account.”

In another scenario, an employee may defer less than the match rate for the first half of a year, and then defer well above the rate for the last six months. In that scenario, Murphy says, employers will average out the match, and apply the difference for the participants.

The contribution is generally completed within the first two months following the new year, but will normally hold a deadline of April 1 because of the length in time taken for later contributions to process, says Murphy. This date can vary by an employer however, and be established as long as it is included in the plan document, is supplied to employees and has been approved.

In the event that a plan sponsor was to miss fulfilling the true-up—a scenario Knowling regards as very unlikely due to the visibility surrounding the process—the plan sponsor would work with either a compliance or legal team on a resolution.  Due to its status as an unrequired benefit, Murphy notes plan sponsors would not face a penalty from regulators should a true-up contribution be missed. However, if written into the plan document, the missed benefit must still be corrected.

NEXT: Popularity of true-ups

During the PLANSPONSOR National Conference in June, poll results showed more than half of sponsors surveyed (55%) do not offer a true-up match, whereas 44% did.

According to Knowling, if the plan sponsor is already automatically enrolling employees at the match rate, participants will less likely see—and need—a true-up match.

However, the number of plan sponsors offering true-up matches may increase in the upcoming years ahead, as a recent defined contribution benchmarking survey from Deloitte found 54% of plan sponsors offered a true-up match in their plan design—nearly a 10% jump from 45% in 2015.

For workforces and plans not offering a true-up contribution, Knowling says plan sponsors can employ education targeting communications to participants on track for missing out on maximizing the employer match.

“If they don’t have the plan design that [provides for] a true-up contribution, there are opportunities with education so that the participant can maximize their employer matching contribution,” he says. “And for those plan sponsors who do have a true-up provision, they have an opportunity to promote the extra benefit.”

IRS Says Missed DC Plan Loan Repayments Can be Repaid in the Following Quarter

Participants can also refinance a loan and replace it with a new loan.

The Internal Revenue Service (IRS) has issued a memorandum on defined contribution (DC) plan loan cure periods for participants who have failed to make installment payments.

On a regular basis the IRS notes that loans, as long as they are not for the purchase of a primary home, can be repaid in five years and that payments are due at the end of the month for the repayment term of the loan.

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But should a participant miss a payment, according to the memorandum, they can take care of that payment by the last day of the calendar quarter following the previous quarter in which the payment was due, the IRS says. They can also refinance a loan—but it will still be due on the original due date.

The IRS gave two scenarios in which a participant missed a payment. In the first instance, the participant made up for the lost payments and in the second instance, the participant refinanced the loan. In the first example, the participant missed their March 31, 2019 and April 30, 2019 payments but makes a payment on July 31, 2019 that is three times their normal payment—which means the participant has satisfied the conditions of his or her loan.

In the second example, the participant misses three payments in 2019, on October 31, November 30 and December 31—and decides to refinance the loan and replace it with a new loan on January 15, 2020. This new loan is still due within the original period, on December 31, 2022, the IRS says. “The participant’s missed installment payments do not violate the level amortization requirement,” the IRS says, “because the missed installment payments are cured within the applicable cure period by refinancing the loan.”

The IRS reminds plan sponsors that the statutory plan loan limit is the lesser of: $50,000, less any outstanding loan balance in the previous year, or the greater of half of the participant’s vested accrued benefit or $10,000.

The IRS’ memorandum on plan loans can be downloaded here.

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