Cross-Tested Document Issue

[PensionPro]

We use a Corbel VS document for a profit sharing plan that allows cross-testing and has each participant in a separate group.

In certain years, is it permissible to use design-based safe harbor allocations and not utilize the cross-testing feature. Specifically, comp-to-comp allocations or TWB-integrated allocations. Unfortunately, younger employees terminate employment when you least expect them.

Thanks for your insight!

[Mike Preston]

Yes.

[Bird]

In theory, yes, you could do this by amending the plan before participants have earned the right to certain allocations. But since you already have the groups set up, just choose an amount for each group that happens to be the same percentage. Then you test on a contributions basis instead of a benefits basis and all is well. You can even give a little more to those over the TWB and impute permitted disparity, and achieve the same results as if the plan had been a safe harbor formula integrating at 5.7% over the TWB.

[Mike Preston]

I think you put more words into your reply and said......."yes".