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  1. Have a new client - all employees are family members and all are HCE. Want to adopt a 401(k) plan for 2018. I know the 3 month rule for safe harbor plans. But for non safe harbor plans unable to find specific guidance. Something from my past says that all participants have to have an effective availability to the Plan. If all HCEs with the ability to bonus out at end of year for 401(k) any issues with adoption in December for a calendar year plan?
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