HCEs participating in more than one of the unrelated employer plans

[Guest kimninh]

I have several HCEs participating in more than one 401(k) of an unrelated employer plans. Do I need to aggregate contributions for the purposes of adp/acp testing?

[MGB]

Not for ADP testing. However, they must be aggregated for applying the 402(g) limit of $11,000. This is an individual taxpayer limit across all plans that they participate in.