Gateway or anything due EEs?

[Earl]

DB Plan has 2 yr eligibility & DC Plan has 1 yr eligibility.

EE enters the DC Plan 7/1/2018.  He has not entered the DB Plan.

Key EE has no DC Plan account addition for 2018.

Is this employee required to get Gateway (or any contribution)?

If Key EE had made a 401k contribution, EE would be required to get DC TH.  Would any additional contribution (i.e. Gateway or 5% TH) to this new DC Participant be required?  

Thank you

[CuseFan]

Gateway is required when you cross-test a DC plan, either on its own or in aggregation. Are you having to do that? If not, no gateway, but if so, then yes gateway is required.

If plans are part of required aggregation group (for TH) - I assume this is the case - you say Key has no DC account addition for 2018, not that Key has no DC account in 2018 - so you have top heavy at 3% if not aggregated for testing or 5% if aggregated for testing. 

[Bri]

Are you sure you have to give 5% for top heavy for a second plan that employee's not a participant in?  I can see the argument for a 5% GATEWAY for testing purposes, but not a top heavy increase for someone not eligible for both plans.

Or if the plan documents say otherwise, too, in their carefully-worded meshing of the top heavy requirement between the two plans.