Top-Paid vs Lookback - 2 plans & different options

[Jakyasar]

Might be inheriting 2 existing plans for 2025, one has top-paid and one has lookback definition for HCE determination.

Too late to change anything for 2025.

Did some research on BL and also Notice 97-45, not sure I located the answer but looks like I can only use "lookback" method.

Will be amending to match during 2026.

Any comments or cites are appreciated.

Thank you

[Bill Presson]

Jak, I’m confused about your concern on the look back definition of an HCE. To me, that’s just the standard way of determining an HCE. 

[Jakyasar]

Hi Bill

It is 2 separate plans in a combo situation. One plan has top paid election to determine HCEs and the other has lookback election definition.

[Bill Presson]

Ahh. Didn’t realize you meant two plans with the same sponsor. 
 

I’ll be curious to see others thoughts.