Key Employee in Association Plan

[KCA]

In determining if a profit sharing plan for an association is top-heavy, is an officer of the association who earned over $165,000 last year a key employee? Obviously, there are no key employees due to stock ownership but is an officer/participant in an association a key employee? I have found references on line that state that the top-heavy rules do not apply to a plan of an association but that statement seems to contradict the Treas. Reg. § 1.416–1, T–15.

T–15 Q. For purposes of section 416, do organizations other than corporations have officers? A. Yes. For purposes of the top-heavy rules, sole proprietorships, partnerships, associations, trusts, and labor organizations may have officers. This rule is effective for purposes of determining whether a plan is top-heavy for plan years which begin after February 28, 1985.