PPA and QMACs in ADP Testing

[Guest esaade]

Section 401(k) of the final regs has a limit on targeted QNEC that can be included in the ADP test. Section 401(m) has a fairly similar limit on QNEC that can be included in the ACP test. It also mentions in pages 78150 and 78152 that there is a new limit on targeted matching contributions, which limits the extent to which QMAC can be used to avoid the new limit on QNEC. Page 78189 of section 401(m) defines the new limits on matching contributions that can be used to satisfy the ACP test. Page 78152 and 78189 clearly specify only the ACP test. The limit on targeted QNEC does mention both the ADP & ACP test, but it doesn't mention QMAC. Where do the final regs mention a new limit on QMAC in the ADP test? Maybe there is none. Our Master Plan alows for QMAC to be made to satisfy ADP test. This QMAC contribution can be bottom-up, flat $ and uniform match %.

Would you be in agreement that it appears we could allocate "targeted QMAC" above the 5% limitation to satisfy ADP test?