401(a)(26) NC and CB

[abanky]

does the 401(a)(26) Minimum benefit have to pass in the cb alone or does the aggregate allocation of the nc and cb have to pass it if we always test together?

[ak2ary]

401(a)(26) must be met by the cash balance alone unless the cash balance/new comp combo is a floor offset arrangement that meets the definition of concurrent offset. In that case the cash balance benfit would still be examined alone for 401(a)(26) compliance but it wouuld be tested on the gross benefit before the offset