Safe Harbor Match & Catch Up Calculation for off calendar plan

[Guest Bob Lees]

Have a plan with a 2/1/05 - 1/31/06 plan year.

We have a participant that made 401(k) contributions of $14,100.50 during the plan year.

For the calendar 2005 he contributed $14,256.04. He had no catchup contributions for the plan year 2/1/04 -1/31/05.

My first question is do I have $100.50 or $256.04 as my catchup for the plan year?

I then need to calculate the safe harbor match without the catchup. Is my catchup based on:

1) 14100.50 - 100.50, or

2) 14100.50 - 256.04, or

3) 14256.04 - 256.04, or

4) 14256.04 - 100.50??