MNO Posted August 21, 2017 Posted August 21, 2017 Plan has SH3% non-elective, discretionary match and an excess- integrated PS contribution formula. Plan is top heavy. Working with a McKay Hochman document and Relius software My understanding is that; the SHNEC satisfies the top heavy requirement for the plan but it cannot be used to satisfy permitted disparity. the Discretionary Match contribution can be used to satisfy the 1st tier of the Excess Integrated Allocation Formula. In Relius, I ran Deferrals, SHNEC, Discretionary and Match contributions. All but two participants deferred at least 6%. Those two participants did not defer a all during 2016. and were employed as of 12/31. Ran a PS contribution, expecting to see that first 3% of PS contribution was allocated to the two participants who did not defer but that didn't happen. It appears that Relius used the 3% SHNEC to satisfy the first step of the excess integrated PS formula. Those with earnings over the taxable wage base received the appropriate allocations and the remaining PS contribution was pro-rata. Shouldn't those two employees have received 3% first, according to the formula. I used the top-heavy first, not top-heavy skim method for allocating the PS contribution. Is my understanding of how the SHNEC can be used incorrect or have I coded the Relius specs incorrectly or is there a limitation in the Relius software that won't permit this transaction without a work-around? Help!
Tom Poje Posted August 21, 2017 Posted August 21, 2017 matching contributions can not be used to satisfy integrated portion, so not sure what you mean by your second bullet point. I've never tried running both a SHNEC and integration on Relius. since you can't use the SHNEC to satisfy integration either, are you able to run the integrated formula first, and the run the safe harbor contribution? e.g. they are putting 50,000 toward the integration portion plus the 3% safe harbor? Lou S. 1
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