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Typically the merger of plans is based on the transaction date of the sponsors of the two plans. I’ve never seen plan custodians (RKs or BDs) able to make a merger/transfer of assets happen on that date. Maybe you have. Just not the world I’ve inhabited. So having the plans merge on X date and the assets transferring within a reasonable period after that just hasn’t been a huge issue.

More typically in my experience, Parent buys Child. Child begins participating Parent's plan on 1/1/2026 (for example). Child's plan merges over a few months later (after a short cooling off period and blackout notices etc). Obviously the possibilities are endless but this seems to be the fact pattern I keep running into. For the reasons I explained above I tend not to have a merger effective date of 1/1/2026. But perhaps that is where we are differing. Probably you guys are merging the plans in on the same date Child begins participating in parent's plan (1/1/2026 in my example). I am treating the merger as a different event on a different date.

Why? As mentioned in a previous thread, if the merger documents are properly defined and executed, the location of the assets is NOT relevant.

50?! i.e 3 hours and 20 minutes per plan? assuming no data issues, all provisions are standardized, everything is passed on the first try and zero time spent on documentation and notes? double that. Here is another tip - in old good times we would put on a wall a large map with multipe colors highlighting the permissive aggregations. Might still be an efficient and relevant tool inspite of all the AI advancement.

Effen is correct - for benefit determination you need not use consecutive but for 415 FAE hi-3 it must be. Also, and this applies to traditional plans with employees that are integrated with social security, you lose 401(l) safe harbor if you use average of non-consecutive years. We took over a plan where prior actuary amended for non-consecutive years for the client (via an "end around" on the AA) but never told them their safe harbor design went away and they needed to general test.