"reasonable" classifications

[Guest CKrum]

We have a client that insists on restricting access to their benefit plan to only their managers. Assuming it could pass the safe harbor testing, would "managers" be considered a "reasonable" classification based on "valid business criteria" as required by 1.410? I have seen examples using hourly vs salary, geographical location and references to "job category" but I'd like to make sure that "manager" would qualify.

Thanks

[Below Ground]

Quoting the The ASPPA Defined Contribution Plan Series Volume 3:... "Reasonable classifications include specified job categories of employees (e.g. secretaries)...." under the chapter for ABT and Special Rules. You can find this on page 5-4 of the 2nd Edition. I think managers are a specific category. Hope this helps.