Top Heavy and Forfeiture Allocation

[Guest Sheryl L]

I have a PSP, no contribution to be made for current PY. There are forfeitures to be reallocated, integrated at 100% SSWB. Plan is top heavy. When allocating the forfeitures, participants are getting 1.9%. One key is getting 1.9% plus 1.9% on excess.

Does the allocation meet the top heavy minimum requirement even though the key is getting 1.9% on his excess? Or should I just allocate 1.9% and ignore the integration?

[Medusa]

It does not meet the TH minimum as outlined. Assuming that a straight pro-rata allocation does not generate an allocation in excess of 3% for anyone, that is what you will need to do.