permissive aggregation - 2 plans with different eligibility

[Santo Gold]

2 large 401k plans are permissively aggregated for 401k testing. Both are calendar year plans, both have eligiblity requirements that are more lenient than 21 & 1. Plan A allows for entry on the first of the month following employment. Plan B has a 6 month wait and allows entry on 1/1 and 7/1.

For the combined 401k test, do I apply the eligibility for each plan separately to determine who is in the test, or do I use the most lenient eligibility (Plan A's) and apply it to all employees, including Plan B. I think the former is right, but would appreciate and comments.

[austin3515]

Test on the basis of otherwise exlcudables and basically ignire anyone with less than a year or under 21 (assuming no 5% owners fall into that category). This basis is almost always the best way to go.