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Posted

I know the Gateway for plans being tested together (Cash Balance & 401(k)) is generally 7.5% (but it's not required).  My question is though, does that 7.5% include the Safe Harbor if it's being done?  We are now installing a Cash Balance Plan, but there is an existing 401(k) Plan that is already giving a 6% Safe Harbor.  

So, I wanted to make sure that to satisfy the Gateway we only needed to give an additional 1.5% into the Profit Sharing?

Thanks in advance!

Posted

Safe harbor non-elective counts toward gateway and rate group accrual rates for 401a4 testing, safe harbor match does not. If your 6% SH is the match it doesn't help you and could hurt the situation. If this is a small professional services employer where you may need to limit DC ER to 6%, the SHM is often a roadblock and can delay CB implementation until the following year, switching SH to non-elective. 

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

Posted

Also they'll get a partial credit towards the gateway from any CB pay credit. 

However, it almost definitely will not be one-for-one, but rather an "equivalent" allocation rate based on the DC testing parameters.

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