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  1. Good morning. I have a plan with 45 HCEs. The plan has immediate entry for 401k. When I test the Otherwise Excludable employees (includes 4 HCEs) separately the test fails. I have 2 questions: 1. Can an HCE be an Otherwise Excludable employee? The McKay Hochman website seems to say No. 2. If HCEs can be an Excludable Employee, do they take a refund, or do I just go with the Non-excludable test, which passes? Thanks in advance!!
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