Safe Harbor and ADP testing

[ejohnke]

I have a plan that is starting a Basic Safe Harbor Match effective 1/1. Their Custodian will not be ready to accept contributions until 2/1. If we make the plan effective 1/1, but deferrals not allowed until 2/1, will they need to do ADP/ACP testing for this first year?

[Bri]

Start the deferrals January 1 and park them in a plan checking account until you can transfer the assets to the new custodian.  Have the self-direction effective 2/1 instead.