(a)(4) testing

[Blinky the 3-eyed Fish]

Two plans of the employer are aggregated for testing. One is a DB and the other a DC. The DB plan's accrual is based on compensation for the whole year. The DC plan's allocation is based on compensation from DOPE.

Would I be able to test using the compensation from DOPE or would I have to use it for the whole year?

[Tom Poje]

1.410(B)-5(d)(5)

"....each employee's employee benefit percetage is the aggregate accrual rate..."

In other words (at least this is what I was taught) you calcualte the E-Bar under the DB plan using its definition of comp, then you calculate the E-Bar under the DC plan using its defintion of comp and aggregate the E-Bars.

[AndyH]

Maybe I'm misunderstanding, because I haven't found Tom to be wrong yet, but I don't think I agree. I agree that each calculation can be separate and can use separate comp, but I think that any 414(s) comp can be used for either plan for testing purposes, and they don't have to be the same, nor do they have to have any relationship to comp for allocation or accrual purposes.

With regard to pre-participation comp, I think you can use this if you use the annual testing method, but probably not the accrued to date.