Non-safe harbor Floor-Offset Plan

[Guest merlin]

If I have a non-safe harbor floor-offset plan am I still permitted to test the DB portion on gross benefits w/o regard to the offset, as I understand I'm permitted to do in a safe harbor F-O? The MP/PS plans have to be included in the avg. ben. test. Any other issues?Thank you.

[Guest el_Leon]

It is my understanding of the rules that you can do it on a gross or net basis. Of course it will almost always fail on a net basis but you can do a combined plan test on a net basis.

when doing the combined basis you have to watch out for most valuable benefits which can be extremely tricky....especially where lump sums are involved. questions such as when to use plan assumptions and when to use standardized assumptions..

I am assuming tha some of the renewed interest in "meaningful benefits"-- 401(a)(26) is not going to cause you trouble, just watchout for new advise on 401(a)(26) and meaningful benefits.

good luck....