DC/DB Combo Top-Heavy Minimum

[austin3515]

I have a DC/DB combo, and we're providing the 5% Top-Heavy Minimum in the DC Plan. Who gets it? Is it only people who work at least 1,000 hours, regardless of their termination date? The eligiblity for both plans is identical.

So for example, I can tell you that anyone eligible for the plan, who was employed on the last day of the plan year gets the THM in a regular DC Plan. Is there a similarly straightforward rule for the 5% DC/DB THM in the DC Plan?

[Tom Poje]

if you work 1000 hours and were in both plans, you have to get the top heavy because of the DB rules

if you work less then 1000 hours but are active and are in both plans you have to get the top heavy because of the DC rules

if you managed to only be in the DC plan and are active then you get the 3% because you don't get the aggregate rules.

[austin3515]

Put another way:

-If you work 1,000 hours and are eligilbe for the DB Plan and the DC Plan you get the 5% THM in the DB Plan.

-Otherwise, you only get the DC top-heavy minimum if you are entitled to it under the DC rules.

Sometimes things make more sense when you get a chance to write them down in your own words. Did I get it right?

[Tom Poje]

maybe. you might have a typo??

the 5% is a dc allocation (you said in the DB).

it either that or 2% Accrual (not contribution) in the DB plan

or prove by comparability that the combo of the DB and DC amounts are equivalent to a 2% accrual in the DB

the documents are suppose to specify, so you have to follow the documents.

[austin3515]

Yes a typo, and in my document we elected the 5% DC THM.

To restate: Because I am going to save this:

-If you work 1,000 hours and are eligilbe for the DB Plan and the DC Plan you get the 5% THM in the DC Plan.

-Otherwise, you only get the DC top-heavy minimum if you are entitled to it under the DC rules.

[Tom Poje]

yes.

see 1.416-1 M-12

again, the document determines (M-15)