We have a case where the client had a db plan for many years, which became very overfunded. A new db plan was created, with the idea of a carve out or offset between the plans. Plan A covers 2 participants and provides a benefit of 6% x service accrual and plan B provides a benefit of 8% x participation. In Year 1& 2, the benefit accrued in plan A is fully offset by the Plan B accrual, and the question is how to satisfy 401(a)(26) for plan A for these years. From what I have studied, 401(a)(26) might not be satisfied until both plans can be aggregated for (a)(26).