General Tested DB + Cross-tested PS

[Guest RSNOW]

What issues or concerns should I have if I want to add and then general test a new DB plan (either cash-balance or traditional) for an employer who already sponsors and will continue to maintain a cross-tested PS plan. Let's assume I don't need to combine plans for testing and will general test each plan separately using the Average Benefits Test for each plan, assuming I can utilize the ABT for each plan without issue.

I realize I must consider 404(a)(7) combined plan deduction limits, and I take into account benefits from all plans in determining ABP for each average benefits test, but are there other concerns or issues to consider that I may be missing ? are additional facts needed ? Thanks for any thoughts.

[rcline46]

You can only use permitted disparity for 1 of the a4 tests, either in the DB or in the DC.