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Posted

I am having a harder than expected time trying to figure out how a safe harbor plan with additional nonelective contributions completes the Schedule T. If the 3% safe harbor is treated like any other nonelective contribution how would you test if 1) all employees are eligible for the safe harbor but 2) only employees with 2 YOS, 1000 hours and employed on last day of year are eligible for the additional nonelective. The coverage percentages is quite different under 2) than 1)

Please help.

Thanks

Posted

I found the answer to my own question, I think. For coverage, you combine the SHNEC and the additonal nonelective (so all NHCEs benefit) but the two contribtions have to be tested together for 401(a)(4). Not a problem if same accrual requirements apply. More of a problem if they don't- may require cross-testing to pass.

Posted

you are correct.

schedue T is simply how many NHCEs got something as compared to how many HCEs. It does not care how much - as you indicated that would be your nondisrim test

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