Is there a 12 month requirement when adding SH coda to a PS?

[Jim Chad]

When adding Safe Harbor to a 401(k) Plan, the first plan year has to be 12 months long. Is there a similar rule when adding Coda to a Profit Sharing Plan? I do mean Coda with a Safe Harbor.

[BG5150]

If a plan doesn't have coda in place, you can add it at any time during the year. In the same circumstances and you want to add safe harbor, the SH must be in place for at least 3 months.

[John Feldt ERPA CPC QPA]

So that means if you add the deferral first, without adding safe harbor, then you can't add safe harbor until the beginning of the next plan year.

But, if you add deferral and add safe habor to the plan both at the same time, the plan year-end cannot be more than 3 months away from the effective date of such provisions being added(October 1 is the deadline for a calendar year plan).

Or are you talking about the old fashioned "CODA" where the company says: here's an amount we're contributing to the plan, but you can make an election to take some of that in cash"?