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  1. As a company, we have a policy of testing plan with comp exclusions for 414(s) first, then using that compensation for ACP testing. However, I do not believe that is necessary. Under IRS regulations, 415 compensation can be used for ACP testing, and, if the plan passes, no further action is needed. I remember seeing posts to this effect. Am I incorrect? Can someone give me examples of reasons 414(s) is needed for a plan with only a match that passes ACP on 415 compensation? Thank you!
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