gateway and combined plans

[abanky]

a db plan which is aggregated with a 401(k) PS Plan for 410(b) and 401(a) testing doesn't have to pass the combined gateway right? Only if the plan was cb in design would a plan have to pass the combined gateway? therefore, since db plan is traditional, we just have to pass the gateway in the ps plan right?

[SoCalActuary]

CB is just a benefit formula in a DB plan.

Gateway testing of combo DB/DC plans requires that you pass some form of gateway, regardless of benefit formula.

How you pass the test is up to you. It can all be in the DC, or primarily DB in nature, or smoothly increasing DC, etc.

But your combo plan has to still get it done.

[John Feldt ERPA CPC QPA]

I'm not so sure about using smoothly increasing rates in the DC plan as a means to say the design satisfies the DB/DC combo gateway requirements. Are you indicating that the existence of smoothly increasing rates takes care of the gateway requirement for a DB plan needs to use the DC plan to pass 401(a)(4)?

[Mike Preston]

Well, it takes care of the DC gateway requirement, anyway.

[John Feldt ERPA CPC QPA]

Yes, I agree with that.