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Applicability of Proposed Regs on Use of Forfeitures to Fund QNECs

Q. Do you know if the IRS proposed regulations on permitting the use of forfeitures to fund Qualified Non-Elective Contributions (QNECs) apply to 403(b) plans? I have seen mention of qualified plans but it appears it may be limited to those under Internal Revenue Code Section 401(a).  

A. It applies to 403(b) plans as well. A comment letter from ASPPA to IRS made the recommendation that it be applicable to both types of plans. QNECs and qualified matching contributions (QMACs) can be written into a 403(b) plan as well, although in most cases a 403(b) plan will only refer to QMACs.