Termination of DB Plan / Qualified Replacement Plan

[J. Bringhurst]

Client is terminating an overfunded DB plan and creating two qualified replacement plans to make up the benefit. One of the replacement plans will be a new DB designed to mirror the terminating DB...the second replacement plan will be the current DC plan that will be amended to provide for a QNEC on behalf of each employee who was a participant in the terminating DB as of its termination date.

The QNEC under the DC plan will cover at least 95% of the participants from the terminating DB who are were employed as of the date the DB plan will be terminated. Under the 95% rule for qualified replacement plans, can any part of the reversion transferred to the DC plan be used to offset future matching contributions (in addition to the QNEC)? About half of the participants in the terminating DB plan will not be eligible for matching contributions under the DC plan. I.e., must both the QNEC and the matching contribution separately meet the 95% rule or is it sufficient that only one type of contribution meet the rule? I know this is probably confusing, but I can't find any guidance on this one.