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Posted

Plan sponsor opened a 401(k) plan effective March 1, 2022 but has been in operation for some years.  It is top heavy as of 12/31/2022 and so the first/short 2022 plan year is top heavy.  I assume the 3% top heavy minimum is required only on pay from March 1 through December 31?  

Posted

I would assume so as well, but you know what they say when you assume...so I would read the document on the definition of compensation for top-heavy but I would be surprised if that wasn't the result.

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