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From my reading of the EOB, I have come across a special rule for processing the ABT for coverage testing. Specifically, it states that if an employer maintains both a DC and a DB, then the ABPT can be calculated separately for both plans (with some caveats). Can someone clarify this rule? Is it as simple as assuming that the ptps in the DB plan only have a zero in the DC plan (for ABPT)? If they are in both plans, does this mean that the ABPT is calc’d solely on the figures in the DC plan? So, if I were to employ this rule for my DC plan, then I would not need any financial information from the DB plan provider, correct? All I would need would be a census listing with the indicative data (if the pops were different) or a count of those who were in the DB, (Not in DC), who met the elig requirements of the DC. Does this sound right?

Finally, if the plans needed to be tested together for the ABPT, is the calculation as simple as converting the DB EBAR to an allocation % and adding it to the alloc % of the DC? (Or converting the DC Alloc % to an EBAR and adding it to the EBAR of the DB plan?)

Any comments/help would be greatly appreciated.

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