Discrimination in Employee Benefit Plans
IRC Section 129 -- Safe Harbor Test

Work-Product Described

This Work-Product actuarially-certifies that the subject Plan (DCAP) is or is not discriminatory (a) without having to account for the prohibited class with respect to eligibility but (b) having to account for the prohibited class with respect to the (i) Benefits and Contributions as well as the (ii) 5% Owners Concentration test and the 55% Average Benefits Test.