HCE Aggregation and Coverage Transition

[Gruegen]

I am curious how the HCE aggregation rule under Reg 1.401(k)-1(g)(1)(ii)(B)(1) is applied during the coverage transition period under IRC 410(b)(6)©.

For example, suppose Company A buys Company B on 1/1/03 and both Companies maintain qualified 401(k) Plans. The plans are intended to be kept separate for non-discrimination testing for the 2003 and 2004 plan years pursuant to IRC 410(b)(6)©. Further, suppose an HCE transfers employment in 2003 between Company A and Company B, earns compensation at each company and makes 401(k) contributions to each Plan - - when performing the ADP test for Plan A, are all contribution amounts added together in computing the HCE's ADP under each Plan?

Or does the coverage transition rule permit each Plan take into account only the deferrals made to that Plan?

Thanks for your help.