The 401k SHPSP provides for pre-tax deferrals, SHM, PS and Davis Bacon contributions. All sources are 100% immediately vested, with the exception of the PS component.
The Davis Bacon contributions are used to offset the employer discretionary contributions (i.e. PS), and included in the general testing,etc,
In order to be able to count the DB contributions and avoid annualization rules, does the PS component needs to be 100% vested also?
Thank you!