Integrated Profit Sharing Allocations

[Connor]

I've been tasked with a 401(k) plan whose profit sharing contribution allocations are integrated with the SSTWB - a first for me.  I realize that this PS allocation method is a type of safe harbor design, though probably not like the popular SHNEC and SHMAC 401(k) designs.  Do you have to do 401a4 testing like when there are new comparability PS contributions in a SH 401(k) plan, or is that not needed because of the integrated design? Any pitfalls to look out for? 

[Bill Presson]

It is a “safe harbor” allocation meaning there is no a4 testing. 
 

The allocation steps will be in the document. 

[Connor]

Thank you for your response, Bill.  I now realize maybe I wasn't specific enough.  I was concerned about how you would take the elective deferrals into account - if the HCEs defer maximum amounts while no NHCEs are deferring (it's a small plan), no testing is needed as long as the PS contribution is allocated on an integrated basis - is that correct?

[Bill Presson]

It’s not safe harbor meaning it eliminates ADP testing. Just means no a4 testing on the profit sharing allocations. The deferrals have no impact on the PS allocation. 
 

It will be something like:

1. everyone gets equal percent up to 5.7% on all compensation 
2. Then anyone with compensation in excess of the TWB gets 5.7% of that comp that doesn’t exceed the max limit. 
3. then any remaining PS money gets allocated pro rata for everyone. 
 

this assumes all eligibility and allocation requirements had already been applied. 

[Connor]

Got it - thx again