Testing 2 401(k) Plans

[wmyer]

A controlled group sponsors 2 401(k) plans, each for a separate location. One has a 2 YOS requirement for match, the other has a 1 YOS for match. Both use prior year testing. For 410(b) purposes, the plans are being tested together. Can you test them together for the ACP test? If so, do you only test those who have 1 YOS at location A and 2 YOS at location B?

[Guest Midas]

If plans in a control group are aggregated for coverage, they have to be aggregated for non-discrimination testing. The aggregated non-discrim testing should be performed the same way an aggregated coverage is performed when two plans have different age and service, which is to use the "combined" method of taking the lowest age and service between the two plans. This affects your coverage group and affects your eligible employees for testing.