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Integrated allocation in Cross tested plan


Karen McIver

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you could test on an allocation basis, and impute disparity and you would pass testing as all should have the same e-bar (assuming you don't have 30% NHCE that receive nothing because last day rule or something like that.)

plus, no gateway since tested on allocation basis

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Karen Mciver, is what you are asking whether you can restructure the plan for testing purposes under 1.401(a)(4)-9(c) into the component plans, i.e. the component plan with the comp to comp allocation and the component plan with the integrated allocation? If each component satisfies ratio percentage, you would not need to satisfy average benefits.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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  • 2 weeks later...

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