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I might have to re-read it a few times but it seems that the prohibited changes are pretty much limited to SH type contributions. It will be interesting to read how the tight-panties group sees it.

Is it permissible for a financial institution to require driver's licenses or other state-issued IDs only from the current state of residence? Wouldn't any ID, issued by the federal government or any state, suffice? Surely a driver's license or like ID from any state in the union must be sufficient under the Patriot Act! How happy is the sponsor with that financial institution? Sounds like there is sufficient cause to find a different institution to handle their plan's assets.

I had researched that with TAG a while ago and got their confirmation that you may exclude non-key HCEs from receiving a safe-harbor match and STILL get a free pass on Top-Heavy.

It's so long I've been reading it for 3 days and I haven't gotten to the end! BTW, it's polite to warn over spoiler alerts like that!