Non discrimination testing

[Gary]

A plan sponsor implements a new Db plan combined with a new 401k/PS plan.

The plan sponsor decides to give each employee up to 5 years of past service when implementing the DB plan and the 401k?PS plan starts contributing allocations from date of participation.

So in other words the employees potentially receive past service credit with the DB plan and not with the DC plan.

In checking the non discrimination on an accrued to date basis is it reasonable to determine the DB accrual based on the total accrued benefit divided by total credited service after the first year of the plan and test the DC plan accrual based on the accrual rate over the one year, since the allocation is only for the one year?

That is, both plans are being tested on an alleged accrued to date basis, but the service can be as much as 5 when testing the DB accrual and is only one when testing the DC accrual.

Thanks.