Leaderboard

Will the HCE plan pass the coverage requirements on its own? If not, then it must be combined with the other plan(s). In that case, all other discrimination testing (ie, as mentioned in Post 2 above) must be done on a combined basis.

Yes there is an RMD. Calculated based on FMV of prior 12/31 I don't see a lot of insurance in plans but isn't insurance past NRA problematic from the incidental benefit rules? You have almost the same "problem" as if the participant's only asset is an illiquid asset. The likely options are distribute the whole policy to participant for full FMV, surrender the policy for CSV or have participant purchase policy from the plan and make RMD out of proceeds.