SHNE - Eligible Participants

[Guest saotampa]

We have a Safe Harbor 401(k) effective 1/1/2007. The effective date for deferrals is 10/1/2007. The plan has 90 days eligibility and quarterly entry dates. There are several participants that terminated employment before 10/1/2007 so they did not have the ability to defer. Do those participants still receive the 3% SHNE? The plan also uses full year compensation. I believe they are entitled to the 3% contribution because the safe harbor provision is effective 1/1/2007.