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I am designing a plan with a short plan year and I want to make sure my thought pattern is correct. I have a plan with a plan year ending on 9-30-2006. There will be a short plan year from 10-1 to 12-31-2006. I am going to define 414 comp as calendar year comp for the short plan year. I am doing this in order to make the ADP for the HCEs low enough to pass. Is there anything I am not considering that would cause me some problems?

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