If a non-union participant in a top heavy DC plan transfers to a union position during the plan year, does he need to be allocated a top heavy minimum? Although top heavy minimums do not apply to union ee's, I thought it might in this instance since he was not a union ee for the entire plan year and he is still employed at the end of the year. If he does need to rec'v a T.H. minimum, would it be based on his comp for the entire year, or just for the portion that he was non-union? Thanks for your input.
