Safe Harbor 401(k) and Top-Heavy

[No Name]

Double checking. Am working on a client that adopted a 401(k) with the 100% of first 4% match. Semi-annual entry dates.

New participant comes in mid-year, defers 4% from entry date (until termination date) and gets matched 100%. Plan is Top-Heavy (except for the exception). Because of the Safe Harbor, I'm thinking I get the free ride from the Top-Heavy rules.

[austin3515]

Long as there's no nonelective money, yes. That incldudes reallocated PS forfeitures (i.e, if there are any reallocated PS forfeitures, your subject to TH).