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Top Heavy Question


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Guest Alwaysthinking
Posted

I have a top heavy plan for the 2002 plan year. The employer is using matching contributions to offset top heavy. There are a few participants that do not defer. The eligibility rules are 3 months and quarterly entry dates.

Can I use statutory exclusions (21, 1 yos) to exclude some participants from the top heavy minimum? The document has all participants employed on the last day. I don't think I can, but...

Posted

many moons ago, on one of these posts, someone 'claimed' to actually have a document that specifically excluded 'otherwise excludables' from top heavy minimums, and supposedly they had a determination letter. I have never seen one of those, and never tried to write a document for approval under those conditions, but I guess you never know....

You are correct, though, generally you have to provide top heavy minimums to those people. It doesn't sound like you have a document that would exclude this group of ees.

Guest Alwaysthinking
Posted

Thanks, that is what I thought. I just wanted a little reassurance.

Posted

I think in order to use match to offset top heavy you would have to have your EGTRRA amendment in place. Lots of plans haven't done their EGTRRA amendments yet and I would think if you didn't have it in place, it could be construed as a cutback issue. Any other opinions on this?

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