Government Pick Up Plans and 415 Testing

[Guest DKE]

A government entity has three plans, a DB, 401(a) DC pick up, and 457(b). My understanding is the contributions "picked up" in the 401(a) DC plan must be tested under 415(b). Would the employer contributions in the DB and 401(a) DC plan be aggregated for for 415 testing? I believe the plans would be combined for this purpose, but I cannot locate any resources that specifically state this is the case.

[Carol V. Calhoun]

Why would contributions (picked up or otherwise) to a DC plan be tested under 415(b)? That section applies only to DB plans.

There is a special rule that employee contributions to a DB plan that are assigned to a separate account are separately tested under 415© (and the benefit generated by them is excluded from the benefit subject to the 415(b) limits). But there is no rule that would make employer contributions (picked up or otherwise) to a DC plan subject to the 415(b) limit.

[Fisher]

So Carol - If the picked up amount in the DB is tested separately under 415©, does it have to be aggregated with any other 401(a) DC plans the participant may be in with that employer?

[Carol V. Calhoun]

Yes, it does.