Auto enrollment & Control Groups

[Guest M. Martin]

I have a control group of companies where there are two separate plans that must be aggregated for testing purposes. The smaller of the two plans is considering adding an auto enrollment feature. Passing the ADP test isn't an issue and so that isn't a motivating factor for them, it would simply be to boost participation levels.

Could Plan 2 implement auto enrollment and not Plan 1 or would there likely be a BRF issue?

Plan 1 has approx 445 HCEs & 2,600 NHCEs provides for 401(k), match & PS

Plan 2 has approx 55 HCEs & 48 NHCEs currently provides for deferrals & PS only

[J Simmons]

In my opinion, the BRF is the opportunity to choose elective deferrals--not the difference of what happens if the employee does not make an affirmative election. So I do not think you would have a BRF issue.