Gateway related

Hi

Friday late, fried brain, cannot think straight. Checking a design for someone.

401k+SH match+PS are the provisions. Plan is top heavy.

401k+SH has age 21 and no service for eligibility.

PS has 21/1. The sponsor will be making a PS contribution (all in their own group). All satisfying the eligibility get the gateway (a little over 3%).

I have 2 participants employed in 2021 (both worked over 1000 hours in 2021) and entered the plan in 2021 and also deferred (I have 5 others employed late 2020 or in 2021 but did not defer). So, they got the SH match. But they do not get PS/gateway as they are otherwise excludable employees. The other 5 who did not defer got no match and no PS/gateway.

Am I correct?

Thank you

You stated the plan is top-heavy. Due to the PS allocation, the plan is not TH exempt, so those whose deferrals are too low to get a 3% of pay match must get a TH minimum. If they are OEE that just means they won’t have to get the minimum gateway, which you indicated is just slightly over 3%.