Top Heavy

[Egold]

If a client has both a defined benefit plan and a 401K plan.

Is the top heavy requirements satisfied by the DB plan if each plan participant annually accrues a benefit of 4% of compensation,

The 401k plan has the 3% non elective contribution, but the plan document says the defined benefit plan will satisfy the top heavy minimum?

[Lou S.]

The documents need coordinating language on how and where the top heavy benefit will be provided. If it is silent, it is likely the top-heavy benefit would need to be provided in both plans.

I would suggest reading both plan documents.

EDIT - though it sounds like participants may be getting both the DC TH-min and the DB TH-min anyway from your description. And if the 401(k) plan says the TH is satisfied in the DB that's fine. 

[CuseFan]

Which plan says the DB will satisfy TH - the 401k document, the DB document, both? It should be both, or at least one w/o being contradicted by the other.

In a DBP, you generally have a 2% TH minimum accrual. If the plan accrues a 4% benefit you should be good. NOTE, this does not mean a 4% credit allocation in a cash balance plan - the benefit accrual must be at least 2% and a 4% credit won't get you there. If that's the case, switch to provide in DC, especially if you're doing another 2% or close to it in PS.