Testing age question

[FAPInJax]

A client has a DC with retirement age 60 (used by the broker for early distribution purposes) and a DB with retirement age of 65. They want to aggregate the plans for testing purposes.

Does this require the testing age for both plans to be 65 (because the definition under 1.401(a)(4)-12 needs to be followed)?

Thanks for any responses.

[Tom Poje]

everything I have ever read said yes, testing age is age 65.

as indicated in another post, if the DB plan was a cash balance (and the DB had the younger retirement age) there may be some other issues involved.