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Super Top Heavy Minimum in a Defined Contribution Plan


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Posted

Does the Super Top Heavy minimum designation change from 3% to 4% when dealing exclusively with a defined contribution plan?

Posted

if there is no DB plan (I assume thats what you mean by saying 'exclusively', then there is no 4%. it is only 3%. and with the new rules in effect, as far as I can tell, , the term 'super top heavy' is no longer applicable begining in 2000.

Posted

To be picky, the term "super top-heavy" is no longer applicable if your plan has adopted the repeal of IRC 415(e).

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

Posted

The entire point of providing a 4% top-heavy minimum is to "buyback" the 1.25 multiplier of the DC and DB dollar limits for purposes of 415(e), instead of being forced to use 1.0 for a top heavy plan. This "buyback" is not available if the plan(s) are super top heavy. Therefore, without a DB plan, there is no reason to consider this extra top-heavy minimum, and with the repeal of 415(e), this becomes a non-issue.

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