Top heavy/Safe harbor plan

[Chippy]

I have a top heavy safe harbor 401(k) Plan. There are deferrals and a 3% non-elective safe harbor contribution. NO profit sharing contribution being made this year. Plan excludes compensation prior to participation.

Is it correct that the 3% safe harbor contribution for a participant that was eligible to enter the plan on 7/1/2015, calculated on his 7/1/2015 to 12/31/2015 compensation satisfies the top heavy minimum for 2015? (As opposed to using his 415 annual comp)

[Jim Chad]

You are covered, but that is not the way I would say it. If deferrals and Safe Harbor contributions are the only allocation anyone received, the Plan is deemed to be "not top heavy".