General Testing of aggregated DB/DC plans

[flosfur]

DB/DC plans are to be aggregated for general testing.

DB's accrual rates are computed using the Accrued-To-Date method. DB grants pre-plan service credits for benefit accruals.

For computing the equivalent accual rates under the DC plan, can the current year accrual method be used or must one use the Accrued-To-Date method?

If the Accrued-To-Date method must be used:

1. What amount must be used in the numerator for computing the annual allocation - actual account balance (which reflects gains/losses, expenses) or aggregate allocations to date minus withdrawals, if any (i.e. ignoring gains/losses, expenses etc)?

2. What comp must be used - current year, average comp during benefiting years or average comp during the period used for the DB plan's average comp (e.g Hi 3).