Compensation For A Cross Tested SHNEC and PS Plan 2 YOS Eligibility

[Stevo-PDX]

Hello Everyone!

We have a new comparability plan with 1 YOS and monthly entry for 401(k) and SHNEC(3%) and 2 YOS and monthly entry for the PS. The plan is also top heavy. We separated out all the otherwise excludible employees and are left with non-excludible employees. Can I get someone’s opinion on the correct compensation to use for each of the 2 example employees below for these test calculations?

Gateway
GND 401(a)(4)
ABPT 410(b)

Participant A: eligible for 401(k) and SHNEC only 7/1. Annual comp is $20k, mid-year comp is $10k. They will need to get a THM of 3% on full year compensation. I'm fairly certain that this is $10k compensation used for all 3 tests.

Participant B: eligible for 401(k) and SHNEC for the full year. Eligible for the PS 7/1. Annual comp is $20k, mid-year comp is $10k. The THM will be satisfied from the 3% SHNEC allocation.

Thank!