Permissive aggregation for coverage testing

[Guest Phil L]

If I wish to permissively aggregate two 401(k) plans for coverage testing, are there any special requirements that I need to be aware of? It appears that both plans may need to have the same plan year and it also appears that the plans must meet the requirements of 401(a)(4) on an aggregated basis.

Anything else that I am missing? What if the plans have different match formulas and or different withdrawal features (benefits, rights and features)????

[Guest]

you have to aggregate for the ADP test and the Acp test.

yes, you will have to perform the BRF test. Of course, if you think about it, it only makes sense - otherwise a company would put two plans in all the time - one for HCEs and one for NHCEs.

Also watch out for possible top heavy issues. maybe thats the one you might have missed.