An integrated plan; top heavy; and 401(a)(4)

[Guest SJPrince]

Say you have an integrated plan that made a 5% of salary integrated contribution. The percent of comp will vary depending on the key/non-key mix and who is over/under the Social Security wage base.

To satisfy top heavy... what do you do exactly? Do you compute each participant's % on an individual basis and look to see who is under the 3% required min contribution? Or can you somehow just go along and fill in the gaps?

I'm not sure on this one... and I am trying to be mindful of 401(a)(4) here. I want to be able to meet those requirements too of course.

[R. Butler]

I would start by looking at the document. Generally the document will be specific as to allocate contributions.

Absent guidance in the document, probably should allocate as follows:

1. Make an allocation of contributions and forefeitures to each participant equal to 3% of his/her compensation.

2. Allocate to each participant's account in the ratio that his/her compensation in excess of the integration level bears to excess compensation of all participants. The integrated allocation should not exceed 3% of excess compensation.

3. Remaining contributions and forfeitures should be allocated to all participants in the same ratio that each participant's compensation plus his/her excess compensation bears to compensation plus excess compensation of all compensation. The allocation under this step should not exceed maximum disparity rate minus 3%.

4. If their is anything left allocate it pro-rata to everybody.