Testing Service Using Accrued to Date Method

[AndyH]

Non-integrated safe harbor unit accrual DB plan is being amended to provide a second tier solely to 10 HCEs.

Plan might change from

1.50% x all YOS to

1.50% x all YOS plus (1.25% of comp exceeding $90,000) x YOS on or after 1/1/2004

Plan has been around for 40 years or so. Is there anything we're overlooking that would prohibit testing the entire benefit over all years of benefit service, i.e. taking advantage of all the safe harbor years now? And I mean anything other than the 35 year cumulative permitted disparity limit.

I think this is fine but would prefer second and third opinions just in case. Thanks.