Coverage/ADP question

[fiona1]

Pretty straightforward question - but I'm struggling with how testing would be handled.

Company A owns Company B, C and D. They are all part of a controlled group (obviously) and each maintain their own 401(k) plan. They all operate on 1/1 plan years.

In 2007, B and D are tested on their own. They were each able to pass coverage separatley - and therefore performed ADP/ACP separatley.

A and C were a different story in 2007. In order to pass coverage, they were permissivley aggregated. As such, they were combined for ADP/ACP testing as well.

On June 1 of 2008, Company A sells B, C and D. They were sold to an investment group and all 3 companies will continue to operate separate plans. In other words, neither B, C or D will merge into any other plans - nor will they merge their own.

So, how would you handle testing these 4 plans for 2008. Keep in mind that A and C had to be aggregated to pass coverage in 2007.

For coverage, I think these plans would be able to rely on the transition rule. Assuming B and D could pass coverage on their own as of 6/1/08, they would be deemed to meet coverage per the transition rule until the end of 2009.

A and C would be aggregated and tested for coverage on 6/1/08. Again, assuming they pass coverage - both plans would be able to use the transition rule until the end of 2009.

As for ADP/ACP, B and D would just be tested on their own for 1/1/08 to 12/31/08. But what about B and D? Would you test ADP/ACP combined from 1/1/08 to 6/1/08 due to the fact the plans are aggregated for coverage for that time period? And then test them separatley from 6/1/08 to 12/31/08?

Any testing experts out there willing to chime in? I think we should have our own testing forum!