Top heavy vs gateway in a combo plan

Hi

Testing 2 plans together for all.

DB and 401k/NESH/PS plans.

Top heavy provided under DC plan only. All participants benefit under both plans.

Key employee is getting 0.5% accrual in the DB and 3% allocation of NESH (plus full deferral), no additional PS for the key.

Combined gateway minimum is 4% (including 3% NESH)

What must I provide to all non-HCE's as additional PS allocation, 1% or 2%?

My vote is 2% but just wanted to check.

Thanks

Yup, it's still 5% total in the DC

What do the documents say? If the documents says the 5% TH minimum is provided in the DC plan than the 5% TH minimum is provided in the DC plan even if it is more than what is required for gateway or 401(a)(4) testing.

Agree, the DC document likely states that the THM is 5% if there is a DB Plan.  Always check the documents for both plans regarding the Top Heavy coordination.  More than likely it is 5%.

I do not put a percentage in the DC plan. Just says DC will cover top heavy.

My plan document has 4 choices for coordinating language. I'm pretty sure you need to address how the T-H minimum is provided if you don't provide it in both plans. This is from our DC plan, but there is similar coordinating language in the DB plan. We almost always use B.

A - The full top–heavy minimum will be provided in each plan (if selected, Plan Section 4.3(i) will not apply).

B - 5% defined contribution minimum

C - 2% defined benefit minimum will be made in the (enter the name of the other plan)

D - Specify the method under which the plans will provide top-heavy minimum benefits for Non-Key Employees:(enter method here) (Must be nondiscriminatory, preclude Employer discretion, and avoid inadvertent omissions).

My doc is different and does not have the same options as yours (I am familiar with your doc's language)

Anyway, thank you all for the feedback.