BG5150 Posted May 1, 2019 Share Posted May 1, 2019 Participant does not qualify for a PS (term < 500 hrs). However, plan fails ADP and he's getting a QNEC in lieu of HCE distributions. Does that QNEC trigger a gateway? QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left. Link to comment Share on other sites More sharing options...
Jim Chad Posted May 1, 2019 Share Posted May 1, 2019 The gate way is just for cross testing. So, no. Link to comment Share on other sites More sharing options...
CuseFan Posted May 1, 2019 Share Posted May 1, 2019 If you have cross-tested PS then I would say yes. Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com Link to comment Share on other sites More sharing options...
RatherBeGolfing Posted May 1, 2019 Share Posted May 1, 2019 Yes. the QNEC triggers gateway even if participant does not qualify for the PS. Link to comment Share on other sites More sharing options...
BG5150 Posted May 1, 2019 Author Share Posted May 1, 2019 So, if it's in the Gateway, is it in the general testing? I thought I read somewhere that ADP QNECs are included.. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left. Link to comment Share on other sites More sharing options...
Tom Poje Posted May 1, 2019 Share Posted May 1, 2019 As I recall, a plan has to pass testing with and without the QNEC. I guess you can't cheat on the original allocation. normally HCEs don't receive QNECs so passing with a QNEC is less of a problem. A gateway is required only if you cross test the allocation. (I don't think simply running the avg ben pct test triggers a gateway) but if you can pass testing on an allocation basis then no gateway Link to comment Share on other sites More sharing options...
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