Prevailing wage as 3% SHNEC

[rcline46]

We know that under document terms, prevailing wage contributions can act as a QNEC for passing ADP testing even though the prevailing wage is not a QNEC and is not subject to the QNEC withdrawal restrictions.

The question is in a 3% non-elective Safe Harbor plan, can the prevailing wage be used as the 3% SHNEC? I am not seeing the stretch although the concept is attractive.

Any thoughts on how this might be accomplished?

THanks for any and all ideas.

[12AX7]

If the client adopted our VS document, the prevailing wage contribution could offset any type of SH contribution, among other employer contributions.