Permissive Aggregation for ACP Test

[Guest jefe96]

A non-profit sponsors a 403(b) plan and also a 401(a) MPP. Only employee deferrals (pre and post tax) go to the 403b. The 401a receives a matching contribution based on the ee deferrals and a fixed MPP contribution. Both plans allow for after tax contributions.

Is it ok to combine both plans for ACP testing? They have similar plan years, etc

[Guest mjb]

please explan how a money purchase plan can adopt a 401k provision. I thought only PS type plans can allow 401k contributions.

[Guest jefe96]

I never said that there was a 401k provision in the MPP. A 401(a) is not a 401(k) provision. After tax contributions are allowed to be made to the 401(a) plan. There are 2 separate plans, a MPP and a 403(b). Employee contributions are the only contributions made to the 403(b) (both after tax and pre-tax). There is a matching contribution made to the 401(a) plan that is based on employee contribution amounts to the 403b. Since the 403b is exempt from ADP testing we only need to run an ACP test on the after tax contributions made to the 403b plan. I am wondering if it is allowed to combine the after tax contribuitons from the 403b and the after tax and matching contributions in the 401(a) for ACP testing.