Hoard1

From looking at 401(a) 4 it seems that the only way to test Plans of controlled groups of corporations with both DB and DC401(k) Plans in the controlled group is under the general test for DB Plans or Cross testing. Any thoughts?

What is the process to test under 401(a) 4?

SLOB may not work because Bank 1 has less than 50 employees. I will look at the exemption your suggested. Pardon my confusion, as long as the individual Plan passes coverage under 410(B) you do not have to look at coverage for all of the plans combined. So, if you had a controlled group of two corporations one with a 401(k) Plan with no ER contribution and the other with a PS Plan with 15% annual contribution as long as indivudual Plans pass 410(B) you are ok for coverage. My impression was that you had to aggregate the plans for your testing employee group and than test each individual plan based on the agregated HCE & NHCE. For example Plan 1 has 5 HCE and 15 NHCE and Plan two Has 3 HCE and NHCE. To test for 410(B) Plan one would be 5/8 or 62.5% and 15/30 or 50%. Plan two would be 3/8 and 15/30 for HCE and NHCE respectively. Under this example the Plans would pass coverage. What are your thoughts?