Safe Harbor Money Purchase Plan

[Guest Mbrockway]

Can a 401(k) plan satisfy the requirements, as it relates to leased employees, of a safe harbor money purchase plan?

For example, if the (k) provides for immediate participation, the contribution is at least 10% of pay, no allocation conditions imposed on the contribution and it was 100% vested - would a safe harbor MPP actually have to be adopted? The only thing missing in the (k) plan would be J&S.

Employer A maintains a (k) plan and leases employees to Employer B. Employer B maintains a SEP and does not want to establish one for the leased employees. Employer A and Employer B are a brother/sister controlled group.

Thoughts/comments are appreciated. Thanks!