HCE's with a plan year change

[Guest CGBS]

I have 401 (k) plan that had a change in plan year in 1999. (It was a 3/31 year end and I did 3/31/99 then I did a short year from 4/1/99 through 12/31/99). The question is do I need now to obtain full compensation for the CALENDAR year 1999 to see who made more than $80000 for my 12/31/00 testing? I was basing my test on people who made more than $80000 during the short period. But I don't think it's right!

Thanks for any help.

[MWeddell]

That's right, you measure compensation during the 12 months prior to the beginning of the plan year, which means during all of 1999 in your case.