Permissive Aggregation of Beginning of Year Valuation Date DB Plan with 401(k) Plan

[Guest Jcarolan]

I have a client that currently has two plans, a defined beneft (PBGC Covered) and a 401(k) Plan.

The defined benefit plan is currently an end of year valuation.

The two plans are permissively aggregated for 401(a)(4) testing purposes.

The client also likes to fund their DB plan on a weekly basis and would like to know their current year contribution by December 1 of the current year, so I am thinking of switching to a beginning of year valuation date to accomdate them, and possibly make AFTAP Compliance less of a mess.

Are there any issues with permissively aggregating a BOY val DB plan with a 401(k) Plan?

Joseph Carolan

[Mike Preston]

None, really. The valuation never had anything to do with the non-discrimination testing anyway, did it?

[AndyH]

There are employer (non-matching) contributions to the 401(k) plan, right? Otherwise you would be permissively aggregating oil and vinegar for no reason.

[Mike Preston]

Even I presumed there were ER contributions of some kind (SH, etc.) going into the 401k plan! If not, you are right, of course.