TPA

Off PYE - 08/31- original effective date of Plan - 09/01/1995 401(k) and 3% Safe Harbor Non-elective effective on 09/01/2019 Plan Eligibility age 19, 2 months elapsed time, 1st of month Part -time employee hired on 01/02/2016 works 2 hours a week cleaning. Has never deferred. On 08/31/2020 was eligible to receive a SHNE contribution. Company wants to amend the Plan to exclude part-time from the Plan now 2 months after new Plan year. 1. My colleagues think that once an employee has met initial eligibility for the Plan and are in that you can't take a benefit away. Is this true? 2. It is too late to amend the Plan for the 2020 PYE. Would it be acceptable to amend eligibility for the Plan for 2021 to be age 19, 1 year with 1,000 hours and dual entry? Would that PT employee still be eligible in this scenario in 2021? Thanks

I want to thank everyone who responded to my message! I needed to show my work since the Plan is audited. I added division codes in Relius. And then I ran the ADP Test by division to get the report that I needed.

I have 4 HCE's - eligible for deferrals and SH - 6.89% I have 88 NHCE's - eligible for deferrals and SH - .76% I tested 33 separately 33 eligible for deferrals and 14 eligible for SH - .17%

OK How do I get Relius to only do an ADP test for only employees who don't receive the SH? That must be what I am doing wrong for the ADP Test to fail.

The amendment has the following: The eligibility requirement for participation in this plan is completion of one Year of Eligibility Service. An Employee in Covered Employment shall become a participant (“Participant”) on the first Entry Date preceding the date the Employee satisfies the eligibility requirements with respect to ESOP Contributions and Safe Harbor Contributions and the first Entry Date following the date the Employee satisfies the eligibility requirements with respect to all other Employer Contributions. Year of Eligibility Service. "Year of Eligibility Service" means(c) completion of at least 1,000 Hours of Service during an Eligibility Period. A Year of Eligibility Service is credited at the time the requisite number of Hours of Service is completed during the Eligibility Period. Does this help?

I have sent the attorney an email regarding the ADP Testing. The Plan is failing the ADP test. The refunds total 39,876.81. I will check the Top Heavy status next. BTW, I was just given the Plan Amendment a couple of days ago.

Individually Designed Attorney Drafted Document - Calendar Year End Plan Prior to 01/01/2019, eligibility for 401(k) and 3% Safe Harbor Non-elective contribution was No age, 30 days, 1st of month Effective 01/01/2019 Plan amended 3% Safe Harbor Non-elective and ESOP eligibility to be The eligibility requirement for participation in this plan is completion 1,000 hours in one Year of Eligibility Service. An Employee in Covered Employment shall become a participant (“Participant”) on the first Entry Date preceding the date the Employee satisfies the eligibility requirements with respect to ESOP Contributions and Safe Harbor Contributions and the first Entry Date following the date the Employee satisfies the eligibility requirements with respect to all other Employer Contributions. Entry Date for purposes of ESOP Contributions and Safe Harbor Non-elective Contributions means the first day of each Plan Year. Entry date for purposes of all other Employer Contributions means the first day of each month. Question - What is the SHNE entry date for someone hired on 02/28/2019 and worked 1,256.93 hours? Is it 01/01/2020? Question-What is the SHNE entry date for someone hired on 06/17/2019 and worked 1,326.69 hours? Is it 01/01/2020? Do you know how I set up Relius to have it calculate the SHNE? Question - Do I have to disaggregate the ADP testing since it has dual eligibility in the Plan now? Plan uses gross compensation (w-2 wages) for testing and allocations. Thanks,

Has there been any relief measures put into place for Safe Harbor Match Plans that are also Top Heavy? Company is looking for ways to manage their costs during this time. TIA