Never dealt with the following as always use 3% non-elective SH.
Existing DC plan with 401k+ADP safe harbor match+PS options (no ps contributions ever made) 10 eligible, only 4 deferring thus only 4 getting SH. Passes top heavy on its own.
Want to add a DB plan and need to combine for all testing and top heavy.
If a participant is in both plans and not getting any allocation under the DC plan because not referring, how is the top heavy allocation determined?
If a participant is excluded from the DB plan and also not getting a SH because not deferring, how is the top heavy allocation determined?
Thank you for your input.