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Safe Harbor Plan and Controlled Group


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Posted

A large (and ever growing) controlled group has several Plans. Some have an Employer Match, some do not. All Plans pass coverage separately, except one which relies on the Average Benefits Test (there is also a DB Plan). All are tested separately for ADP/ACP.

One Plan wishes to be a safe harbor plan. Is there any problem with one plan in a controlled group becoming a safe harbor Plan? Is this addressed anywhere? I see the references in notice 98-52 to aggregation and disaggregation but it does not specifically address controlled group.

If an HCE transferred from the safe harbor plan to a plan in the group that does not have a match would the match have to be refunded to him? Would any problems of this nature be solved if HCEs were prohibited from receiving a match?

Thank you!

  • 2 weeks later...
Guest jigpsu100
Posted

cxs, I have the same question. Has anyone responded to you? I have two companies in a control group and want to put a 401(k) safe harbor in one of them. Thanks.

Posted

No, I have not received a reply. I have contacted an attorney; if I get an answer I will post it.

Thanks.

Guest jigpsu100
Posted

no, thank you!

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