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403(b) combined with New Comp plan


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I don't have experience with 403(b) plans, but will soon enough. A client has a 403b plan and would like to possibly add a new comparability ps plan. I see the previous topic discussion where it is ok to add a MPPP and keep the 415 limit whole for the ERISA plan. First question is can a New Comp plan be paired with a 403b and if so....Would i have to consider the deferrals to the 403b plan when perforning non-discrimination testing on the New Comp plan, specifically, the average benefits test?? Any other thoughts or tips would be greatly appreciated. Thanks.

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Here is my take on it. Take this as one view, not absolute fact.

The 403(b) is completely ignored for purposes of testing an a(4) plan, with the exception that they share a common 402(g) deferral limit.

The a(4) plan can be combined with the 403(b) plan for purposes of testing coverage of the 403(b) plan, but not for testing for nondiscrimination.

Other interpretations?

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