timofeo Posted April 23, 2020 Share Posted April 23, 2020 Looking for your superior knowledge. Client, Comp A, has sponsored a safe harbor 401k (w/Basic SH Match) since 1999. Owners of Comp A purchased another business, Comp B, back in 2010, and never let us, the TPA, know. Comp B has sponsored a traditional 401k (w/ 50% of 5% discretionary match) since 2003. Comp A and Comp B are a Controlled Group. Plans DO NOT pass 410b independently on their own so I need to test them together. What recommendations do you have for me to fix the situation? I appreciate your excellent insight. Link to comment Share on other sites More sharing options...
MWeddell Posted April 27, 2020 Share Posted April 27, 2020 You are not allowed to permissively aggregate 401(k) and 401(m) arrangements that have different testing methods, e.g. one plan is 401(k) / 401(m) safe harbor and the other uses ADP / ACP testing. If Comp A and Comp B are indeed members of the same controlled group, then the client is looking at years of corrective contributions to fix the coverage testing problem and a VCP filing. Link to comment Share on other sites More sharing options...
timofeo Posted July 1, 2020 Author Share Posted July 1, 2020 Thank you MWeddll for the response. That is what I kept running into. I appreciate you taking the time to respond to my post. Link to comment Share on other sites More sharing options...
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