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Posted

If there are no HCEs in the plan, and each participant is in their own group.

Can some of the NHCEs receive an allocation, and others do not?

There are no key employees in the plan.

Posted

If there are neither HCEs nor key employees covered by a plan, unless the plan has to be aggregated with another plan that does have HCEs or key employees, isn't the plan essentially exempt from all testing, top heavy etc.? You cannot have discrimination in favor of HCEs if there aren't any.

Always check with your actuary first!

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