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Same here. It is reasonable for many of them to do it on the payroll date, and it it is pointless to make the correction process longer (especially if the client is paying for the time) when the difference is in pennies.

There are a lot of things to be concerned about in plan operations. This is not one of them. Seriously, it's fine.

Eh, I'm going to disagree. If you do not have reliance on the safe harbor, its back to earliest date when it could have been segregated from employer assets. You don't get the 7 days as a freebie if you don't qualify for the safe harbor.

As far as I know there can be common control. It can be something very obvious. I once had as a client a not for profit hospital group that owned 100% of the stock of a for profit insurance company and they owned 100% of the stock of a for profit medical management group. This rather old article seems to say outside of my example it might be very hard to get common control. I guess based on this I would be careful if one of the groups can remove officers and board members of the other pretty much at will. But even then it sounds like it isn't obvious. https://benefitslink.com/cgi-bin/qa.cgi?n=288&db=qa_who_is_employer

Austin - as far as I know, a for-profit and a tax exempt entity CAN be a CG. Or I guess it is "Common Control" but has the same effect. See, for example, 1.414(c)-5. But assuming they are not, I'm not aware of any reason they couldn't be a participating employer as a MEP, if your document allows it. This is just off the cuff, from memory, so caveat emptor. I'd definitely have to spend some time doing some research before I'd venture a solid opinion on this.

If she properly elected irrevocably to be out of the plan, she is a non-benefiting employee for 410(b). My understanding was that the irrevocable election needs to be done prior to plan entry but I honestly haven't double checked that in quite some time, I could easily be wrong on that. In small plans, allowing irrevocable election to not participate can cause demographic failures that may be difficult to cure through retroactive amendments expanding participation. As for SH I'm not sure the implications on allowing a NHCE to irrevocably elect out of the plan, if it's an HCE you're fine, if it's an NHCE I honestly don't know what that does to your SH status.