Catch-up and the short plan year

[Guest PAL100759]

I have a 9/30 plan year end and am getting ready to change to a 12/31 plan year end. The plan provides for CUC however, under the 9/30 year, participants were only permitted to make CUC between 10/1 - 12/31 if they met a regulatory limit - not because of a plan limit (which applies to the HCE only).

I will now have a short plan year that will end 12/31/04. I'm thinking that I will now be able to permit the HCE to make additional CUC in excess of the plan limit during this period. Does that sound correct? Am I missing anything?

PAL