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I have a situation where a company had a 401k plan (less than 5 years ago), terminated the 401k Plan, entered into a PEO-style MEP for a couple years, decided they did not like it and decided to leave the MEP to start up a brand new 401(k) plan.  The owners of the company transferred all their money into the MEP years ago (I'm not certain all the employees did as the original plan termination was likely a distributable event).  All of the employees rolled their balance from the MEP into the new 401k plan (greater than 60% are owner assets).  I'm currently classifying the rollovers into the new 401k plan as Related Rollovers.  The issue I'm grappling with is whether or not the plan is Top Heavy on day one of the new 401k plan.  I'm looking for advice as to how I should treat this.  If I'm leaving out any pertinent details, please let me know.  Thanks in advance!

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