In a top-heavy plan, which group is typically subject to minimum contribution requirements?

• A. Non-key employees
• B. Plan sponsors
• C. All participants equally
• D. Key employees

Answer: (A)

When a plan is top-heavy, benefits are concentrated among key employees, so rules require that non-key employees receive a minimum level of contributions or benefits to ensure they share in the plan. This minimum contribution requirement is targeted at non-key employees, not at plan sponsors or all participants equally, and key employees are typically exempt from this minimum because their prominence already drives the top-heavy status. Plan sponsors must fund to meet this rule, but the requirement specifically applies to non-key employees.