Top Heavy & Permissible Withdrawals

[Jean]

Would a first year 401(k) plan that is a eligible automatic enrollment arrangement include permissible withdrawals in the test balances?

[Guest Cinco]

Would a first year 401(k) plan that is a eligible automatic enrollment arrangement include permissible withdrawals in the test balances?

Have you found anywhere that says that permissible withdrawals are included as a withdrawal for top-heavy purposes? I'm not finding anything. I think the intention is to pretend the auto deferral never happened. Regs don't seem to address this. I think the most conservative thing would be to not include them because you would think that mainly non-key employees would request a permissible withdrawal.