MRD from ESOP/PS Plan hybrid

[Guest Jose Rosario]

An ESOP plan and PS plan are to be merged into one plan. The surviving plan will retain both ESOP and PS provisions. For purposes of coverage testing, the ESOP portion will be considered a separate plan from the PS plan, notwithstanding that the surviving plan will file a single 5500. For purposes of MRDs, will the plan be considered a single pension plan or will the ESOP and PS portions be considered separate plans that must meet the requirements of 401(a)(9) separately?