General Test SEP w/DB plan ?

[JAY21]

Does anyone see a problem with aggregating a SEP with a DB plan for 410(b)/401(a)(4) testing ? Can you do that ? I realize I'll have the 404(a)(7) deduction limits since I have a common participant, but assuming that isn't too restrictive can I do this ? Thank for any input.

[AndyH]

I suggest you do a search. There are several discussions related to this. I believe that the general consensus is NO, a SEP may not be aggregated for 401(a)(4) testing because it does not meet the definition of a "plan" under 401(a)(4).

[jquazza]

I thought one of the requirement for a SEP (at least if using the 5305-SEP) was that the employer could not maintain another QP?

[JAY21]

That's true on the plan doc issue but this client appears to be using an investment prototype SEP doc and not the IRS model SEP doc.