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Only assets in a new plan right now are unrelated rollover funds. Owner/Employee A takes a loan from the plan.

Now my top heavy test is indicating that the plan is top heavy because of the existence of the loan. Top Heavy test is excluding the remaining unrelated rollover assets, but not the loan. Is this right?

Posted
Only assets in a new plan right now are unrelated rollover funds. Owner/Employee A takes a loan from the plan.

Now my top heavy test is indicating that the plan is top heavy because of the existence of the loan. Top Heavy test is excluding the remaining unrelated rollover assets, but not the loan. Is this right?

No. The loan is an asset in the unrelated rollover source. Cash (an asset) left the plan, the loan (a receivable) is also an asset. The entire accrued benefit did not change. The only change is between cash and a receivable.

Good Luck!

CPC, QPA, QKA, TGPC, ERPA

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