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I have plenty of experience taking over "solo-401(k) plans" from the specific recordkeeper mentioned in this string. Most have had significant compliance problems. My top-3 favorites: 1. Plan doc was set-up with no service requirement. Plan sponsor hired two part-time employees who were working 100 hours per month. There was no TPA so nobody bothered to ask about employees. 3 years later an advisor who knows what they are doing is hired and calls their favorite TPA because something smelled fishy. 2. The recordkeeper allowed the plan sponsor to take a loan from their 401(k) plan with a 1% interest rate (not prime + 1%, but exactly 1%). 3. Exactly what BG5150 mentioned in this thread - the recordkeeper allowed the plan sponsor to dump in the 415 limit every year even though the compensation could not support the deduction (this went on for 5 straight years). Long story short - always use a TPA.

I'm with Lou S. - it sounds like a traditional enhanced safe harbor match with automatic enrollment. No need to overthink it. If it was QACA the AA would specifically say that it is QACA. The only significant difference (based on the information you provided) would be the possible 2-year vesting on the match and auto escalation if the auto enrollment wasn't at least 6% from the start.

QACAs have their own match schedule, deferral escalation rules, vesting requirements. (Though I think the match is immediately vested as opposed to QACA NEC which can be 2-yr cliff)

It sounds like you have a safe harbor 401(k) plan with an automatic enrollment feature. I'm not seeing a problem. Am I missing something?

Here's one: http://www.datair.com/rates.htm Originals are in IRS Revenue Rulings: https://www.irs.gov/retirement-plans/revenue-rulings

That is the key. Typically, unvested balances forfeit at the earlier of distribution of vested balance or 5 consecutive one-year breaks. If you have unvested balances remaining for participants who have been gone longer than five years then you could have a compliance issue - operational defect for not following plan document that may have required forfeiting and re-allocating (or reducing ER contributions) in a specific time frame. You should make sure that is clean before terminating the plan. Then, anyone who has not forfeited unvested balances under the terms of the plan must be fully vested upon plan termination.

What does the plan document say about when forfeitures occur?