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Roughly sixty employee company, half of the eligible are deferring, 50% of first 5% match, bad ADP and ACP but not close to being Top Heavy. A Plan is going to start Safe Harbor Matching in 2015 (Enhanced Formula). I'm designating that Pre-2015 matching accounts (non-safe harbor) remain subject to vesting. Forfeitures may happen after 1/1/2015 in these prior accounts. If the amount of forfeitures is greater than Plan expenses, it would be great if they could be used to fund (reduce) some of the Safe Harbor Match. The document we use is from one of the big providers and an adoption agreement provision is "Forfeitures will be used in the following manner:" (check box) "Any permissible method (restore forfeitures, reduce Company contributions (or reallocate as Company contributions) made pursuant to Article 4 or to pay Plan expenses)". In response to a query of whether the forfeitures could fund part of the Safe Harbor Match, the document provider said: "There is nothing in the plan document that specifically prevents forfeitures to be used to fund safe harbor contributions but the IRS has noted verbally that they do not agree with that position and will be providing clarification in future regulations. At this point it is a plan by plan decision on if they want to proceed with using forfeitures to fund safe harbor contributions." I'd prefer to a) reduce (fund) the Safe Harbor contribution by the forfeitures, b) If plan expenses could soak them up, I'd like pay then, or c) allocate to those deferring in some proportion Any experiences anyone would like to share?