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FWIW, we used the C3 restatements to change all our plans to IRA rollover on force-outs just so we wouldn't have to deal with this anymore.

1. A nitpick must be precise to maintain its integrity, authority, and fastidiousness. 2. There was no need to cavil with the statement itself. 3. I am such a bad typist that it was easier to copy and paste than paraphrase.

You may want to refer to Situation #4 in Rev. Ruling 2004-13 as it addresses the otherwise excludable employees and top heavy. You do not get the top heavy exemption since some employees who are eligible do not get the safe harbor non-elective. https://www.irs.gov/pub/irs-drop/rr-04-13.pdf Also - Starting in 2024 (plan years after 12/31/2023), SECURE 2.0 changed the OOE rules and top heavy and the otherwise excludable employees are not required to receive the top heavy minimum.

How could it not? From various organizations letters to Labor and Treasury, there are many requests for technical corrections and guidance on SECURE 2.0. If those go unanswered for an extended period, practitioners end up functioning in the dark, making educated guesses, or simply not acting at all. Also, what about determination letter and plan termination filings (IRS and PBGC) that could get substantially delayed? This doesn't even consider the implications from the general economic meltdown that could happen. Any government shutdown and default would be bad for everyone, except maybe the handful of politicians whose election platforms were to blow up the economy.