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Posted

Employer wants to exclude a class of HCEs from the ESOP plan or any DC plan for that matter (this class of HCEs has suggested this) from receiving employer contributions for one year. These HCEs are already eligible participants. It is my understanding you can amend the plan for an employment classification exclusion as long as you can pass the coverage requirements under 410(b). Since your discriminating against HCEs, there will be no problem passing the coverage testing. Any issues with this?

Posted

Almost no. Only if the HCE's have already accrued a benefit will there be problems.

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