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Top Heavy with dual eligibility for deferral and safe harbor


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I need some help

i have 3% nonelective safe harbor plan

eligibility for deferrals is 6 months with quarterly entry.  eligibility for safe harbor is 1 year with quarterly entry.  plan uses entry date compensation for those that enter mid-year

The plan is top-heavy for 2020.  I know I have to give the top heavy contribution to those that are only eligible for deferral, to satisfy top heavy.

I assume i need to make an additional contribution to those that entered mid year for the safe harbor, so that they receive 3% of full year compensation. 

is this correct?

Thank you for your time!

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That is correct - every non-key employee who is in the plan for some portion/money-type and is employed at year-end must get at least 3% of annual 2020 compensation from employer contributions to satisfy top-heavy.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services


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