Safe Harbor Match

[FJR]

Just checking on what other TPA's are doing when they administer SH Plans under the following.

Large Company who sponsors SH 401(k) Plan. Demographics are many min. wage salaried employees, few management and a few owners. Company gets SH notice out to EE's offering a basic SH Match. In addition to notice to EE's, they go through a very thorough enrollment meeting. Results - Owners want to Max out their 401(k) contribution, Managers as well. Of the 70+ eligible min. wage workers 7 sign up to defer. Here is the question. What are TPA's doing about the following:

1. Proof that the SH notice was given

2. Are you getting enrollment forms back that indicates the other 63 eligibles decline defering. If so, is that impartive

Anything else missing regarding admin to a 401(k) SH Match? My concern is about the low participation, yet allowing the owners and other HCE's to max out.

[Tinman]

We ask plan sponsor to send us copy of notice when it is complete (we send them one that needs them to fill in a few items before posting/distributing) and keep the copy with their adoption agreement.

As far as low participation, you can set up an administrative policy to get enrollment forms where employees indicate they don't want to participate, but are you going to get them from everyone each year? Maybe just have the employer keep them on file if you feel the need to have them completed.

Obviously you can't force participation, so provided the notice is properly delivered and the employer is following a set procedure for soliciting all employees to participate, I'm not sure there's much else you can do.