Testing age for DB DC combo?

[Guest Arlingtonray]

NRA under DB plan is 65. NRA under DC plan is 62. Is it ok to aggregate the two plans for general testing purposes and use 65, the later of the two uniform retirement ages, as the testing age for all particpants in both plans?

One person told me I need to amend the DB plan to have a NRA of 62.

Thanks in advance for any comments.

Arlingtonray

[WDIK]

The following discussion may be of some help.

http://benefitslink.com/boards/index.php?showtopic=29430

[Blinky the 3-eyed Fish]

While I agree that you can use age 65 for testing for the reasons you describe, be careful that you don't have any BRF issues with differing retirement ages. If for example, a much higher percentage of NHCE's had larger benefits in the DB plan, the fact that they have to wait until 65 to receive a distribution could be an issue. Now generally the opposite is true and more HCE's get higher benefits in the DB, so you may be okay. Just keep it in mind.

Of course amending to 62 makes everything all warm and fuzzy.