Offsetting Employer Contributions with Safe Harbor (Question C.15e.) Offsetting Employer Contributions with Safe Harbor (Question C.15e.)

Offsetting Employer Contributions with Safe Harbor (Question C.15e.)

This provision was added to our PPA documents at the request of a customer and was carried over to our Cycle 3/Post PPA documents. It is not very commonly used.  The purpose would be to offset a profit-sharing contribution by a safe harbor non-elective contribution.  

For example, where a plan excludes HCEs from the safe harbor non-elective contribution and has a pro-rata profit sharing formula, the employer could choose to give the same 3% as a profit-sharing contribution to just the HCEs. This results in a  total 3% employer contribution to all employees consisting of safe harbor non-elective to the NHCEs and profit sharing to the HCEs.   

NOTE:  this provision would not need to be elected  to include safe harbor non-elective contributions towards top heavy, gateway, and rate group testing in plans with a new comparability profit sharing formula.