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Top Heavy in DB plan


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Aren't non-ERISA plans exempt from ERISA?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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Non ERISA church plans are subject to the Internal Revenue Code. Section 401(a) does not exempt them from the top-heavy requirements. They are subject to these rules. This prevents qualified retirement plans from being sponsored by a bogus church and stuffing the key employee benefits at the expense of the non-key.

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