In a plan effective 1/1/99 that covers a participant who's 75 years old and an HCE, is there still a 401(a)(9) requirement if the contribution will not be made until after 4/1/00? Or must the employer make the contribution before 4/1/00 so that this HCE can be paid his MRD (since contributions, no matter when they're made, are deemed to be in the plan as of 12/31/99)?