Plan has 2 HCE's. One is very old (owner) and the other is very young (son) and one NHCE in the middle from an age standpoint.
As I understand it, the SHNEC causes two problems with an age weighted plan. First, the EBAR will no longer be the same for all participants so they don't get the automatic pass on cross testing that a normal Age Weighted P/S would get, which forces me to perform the cross testing. Second, the plan will no longer meet the broadly available allocation rates so I will have to make sure they all get the gateway minimum. Is this correct?
With all of that said, I still allocate the P/S contribution based on Comp * Actuarial Factor (disregarding the 3% SHNEC). Correct?
Is this why they say that two safe harbors don't make a safe harbor?