New Comparability PS Allocation In SH 401k

[mming]

Not sure if I have this right. A top heavy 401k plan uses matching contributions to satisfy the SH requirements. A PS contribution will be made with the owner getting over a 15% allocation, so a 5% gateway applies to the NHCEs. The SH match can be used towards both the gateway amount for the NHCEs and the 3% top heavy contribution for the non-key HCEs. The matches and PS allocations are combined for each participant to calculate the EBARs/rate groups, and the deferrals are then added to those totals for the average benefit testing. Is this correct? Thanks in advance for all assistance.

[Tom Poje]

the only contributions that count toward gateway would be nonelective, so I dont believe you can use the safe harbor match.

That is a SHMAC rather than a SHNEC.

In the same vein, for rate group testing you only use nonelectives. since a SHNEC is a type of nonelective it is included, but not the match.

for the avg benefits % test everything is included.