2 types of ER contributions - vested sched vs immediate

[TPApril]

Plan Sponsor has asked for 2 employer contribution types, with similar eligibility, as follows:

• Individual rate groups - this would be immediately vested
• prorata allocation - this would be subject to a vesting schedule

There are no HCE or key employees receiving contributions. Contemplating plan design options, but not sure I'm seeing it in the volume submitter document we're setting it up with.  Is it as simple as setting the first contribution as a QNEC?

[K2]

This is a good question for your document provider.

[BG5150]

Setting the first one up as a qnec is an option, but keep in mind the withdrawal restrictions.

[CuseFan]

Are there no HCEs getting current allocations or no HCEs in the plan? If you have HCEs and they get future allocations from the individual rate group formula then you could have a BRF issue regardless if gateway and NDT were satisfied, unless NHCEs received similar allocations that were fully vested.