Safe Harbor Discretionay Match Top Heavy

[sdix401k]

I need to confirm that an addtional discretionary match made in a Safe Harbor plan ( that meets all the requirments for passin acp ) would then cause a plan to be top heavy.

In essence even though the plan satifies ADP / ACP from Safe Harbor Contributions does the act of making this addtional discretionary Safe Match cause the plan to now be top heavy tested?

Thanks ina advance.

[Tom Poje]

100 % confirmation is impossible at this time.

at least one IRS official insists this would be the case. (I believe the reason being is that the discretionary does not satisfy ADP - it is an 'additional' contribution)

However, individuals at Corbel would disagree, since the discretionary does indeed meet ACP safe harbor on its own.

they keep promising to release some type of guidance on the issue.