I think it is pretty widely accepted that even owners with less than $100K of comp get the credit. if you look at the text, the words "NHCE" do not appear anywhere in there (its not very long). It only says people with more than $100,000 of comp are not eligible.
I'm really talking myself into this...
Lou and Peter are spot on. Discretion for consistent and reasonable interpretation of vague plan provisions, not for exceptions. Also, a vague provision does not give carte blanche on interpreting any way the PA desires, it must still be reasonable.
I've read many lawsuit summaries where the PA was sued alleging its interpretation was arbitrary and capricious (legal term for willy nilly).