Avoiding gateway in DB/DC combo

[R. Butler]

I do very little with DB plans, so I'm hoping to get some verification on this.

It is my understanding that a DB/DC combo. is elgibile to cross-test if it "is primarily defined benefit in character". A plan will be primarily defined benefit in caharcter, if for more than 50% of benefiting NHCEs, the normal accrual rate for the NHCEs under the DB exceeds the equivalent accrual rate under the DC plan for the same employees.

We are looking at a combo plan where there are 63 NHCEs. 33 benefit under the DB plan; 30 benefit under the DC plan; no NHCE benefits under both plans. If I am understanding correctly this would be considered "primarily defined benefit in character". Does this sound correct?

Thanks in advance for any guidance.

[Blinky the 3-eyed Fish]

Correct.