Cash Balance Plan on top of 401k w/ X-tested PS plan

[dmb]

For the Cash Balance plan, if the formula provides different benefits for different classes of participants, does the Cash Balance Plan need to pass the Rate Group Test if all plans pass the average benefits test and the Gateway DB/DC combo.

[Mike Preston]

In a word, yes. The ABT and the gateway are merely parts of the puzzle. They do not provide a safe harbor for the rate group test.

[dmb]

Thanks. So does that mean the Cash Balance plan must pass the rate group test based on cross testing (allocation rates) or could it be tested on accrual rates??

[Mike Preston]

It can be tested in any way that you want. That is, the fact that it is a cash balance plans does not restrict the testing methods to anything in particular. You would test it any way you could otherwise test any defined benefit plan.

[dmb]

Thanks again. I sent you an e-mail asking if you had a few minutes maybe we could speak on the matter. Please let me know if this would be possible. Thanks.