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Posted

Hot and humid, not thinking straight.

Checking a proposal for a DC/CB combo

DC is 401k+SH Match+PS

A previously employee claimed to be an HCE turns out to be a NHCE. Let's call him Joe

Joe is excluded from CB plan and also gets on no PS under DC plan. 401k deferral generated enough SH match to exceed 3% of salary so top heavy is satisfied.

Plugged this into the program and combined testing says Joe does not need to get gateway.

Just checking is the program is right.

Posted

Correct - he only is required to get gateway if he benefits under 401(a) portion(s) of the plan(s) (non-elective - CB & PS). Since he gets no CB or PS under the terms of those plans then he does not benefit, so no gateway.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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