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Need Help with 401 (b) Calc


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Company has 2 401 (k) Plans. Plan 1 benefits only the employees of Division A. Division B is excluded by class. Eligibility for this Plan is age 21/1 year of service and the entry dates are 01/01 and 07/01. Plan 2 benefits only the employees of Division C. There is no age/service requirement and the entry dates are 01/01 and 07/01. The plans are combined for purposes of 410 (B).

With the following data, can I assume I pass the ratio percentage test on a combined basis?

Plan 1:

Total Employees 1183

Total Excludable 1091

NHCE's Benefiting 71

NHCE's Not Benefiting 163

Total Nonexcludable NHCE 234

HCE'S Benefiting 21

HCE's Not Benefiting 0

Total Nonexcludable NHCE 21

Plan 2:

Total Employees 453

Total Excludable 149

NHCE's Benefiting 304

NHCE's Not Benefiting 0

No HCE's in this Plan

Since the two plans have different eligibility requirements, I'm not sure which employees are excludable when testing on a combined basis.

Thanks.

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