Multiple 403(b) plans from different institutions and the annual additions limit

Dear Sir/Madam,

I have a client who has taught at two different universities this year and he has participated in two 403(b) plans. We are clear that he cannot exceed the salary deferral limit of $19,500 plus the $6,500 catch-up contribution when combining his contributions between the two plans.

Are his total contributions (including the employer contributions) combined between the two 403(b) plans limited to $64,500 ($58,000 plus the $6,500 catch-up contribution)? Or, do we just need to be concerned with the salary deferral limit?

We’ve seen in the Apr 2020 newsletter covering multiple retirement plans that multiple 401(k) plans with unaffiliated employers allows clients to “double-up.” However, the same newsletter states that multiple 403(b) plan contributions are limited.

There is one other wrinkle with this. The current 403(b) plan where he is receiving employer contributions is a mandatory retirement plan based on the state where he is working. Does the mandatory nature of the plan allow him to receive more in the way of contributions?

Thanks,

Chris



From IRS Publication 571, Chapter 3, Page 5:
More  than  one  403(b)  account.  If you  contributed  to  more  than  one 403(b)  account,  you  must  combine  the contributions  made  to  all  403(b)  accounts  maintained  by  your  employer.  If  you  participate  in more  than  one  403(b)  plan  maintained  by  different  employers,  you  don’t  need  to  aggregate  for annual addition limits.
 

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