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Thank you.

This is correct. Whether a person is considered "eligible" for deferrals (adp) or match (acp) will depend on that person's class (and whether he is a member of an excluded class; for example hourly). However, coverage under 410(b) is tested against safe harbor excludable classes (i.e. union). So, if the individual is excluded (say for being hourly), he would still be included in 410(b) because hourly is not a safe harbor exclusion like union or non-resident alien. Good Luck!