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Posted

Plan is a Safe Harbor 401(k).

Employer makes the Safe Harbor match contribution.

The only conts to the plan are deferrrals and Safe Harbor match contribution.

Client wants to know if top heavy is satisfied by the Safe Harbor match contribution?

Is an additional contribution necessary for those participants who do not contribute and, therefore, do not receive the match contribution?

Any help is greatly appreciated.

Posted

As long as the only contributions to the plan are deferrals and safe harbor match, the plan is deemed to satisfy the top heavy minimum.

/JPQ

Posted

Reallocated forfeitures would take away reliance on the top-heavy pass. Also, if you have different eligibility for deferrals than for safe contribs. (i.e. immediate entry for deferrals, 1 yr wait for s. harbor) you don't get the top heavy pass.

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