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| Is Top-Heavy Minimum Required in This Situation? BenefitsLink Message Boards  Jan. 29, 2021 "We have a new 401k/PSP plan with an effective date of 1/1/2020, but a special effective date of 11/1/2020 for 401k deferrals and safe harbor (3% non-elective) contribs (it was adopted late in the year), so the 401k and SH provisions were just effective for the last two months of the year (from adoption date forward). Note -- the plan will be top-heavy. If the only contribs for the year are the two months of deferrals and the SH 3%, will the plan be deemed to satisfy top-heavy minimum? Or will the employer need to top off all employees at 3% of comp for the entire year?" |
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