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Guest DBStudentAct
Posted

Just started with my first Aggregate testing.

The client has a DB plan along with a PS, 401(m) & Deferrals. I am aggregating all of them and testing on a benefits basis.

The software we use includes all the 3 DC values for the 410(b) testing but includes only the Profit sharing for the 401(a)(4). I thought the match should also have been included for the test? I know that the deferrals are not to be included for sure but as far as the match goes I am confused.

Also just wanted to confirm if the Deferral has to be capped at $15.5K for 410(B) even if the participant is more than 50 years old and has deferred $20.5K?

Any help will be highly appreciated.

Posted

The match is not included in the Nondiscriminatory Classification Test (i.e. the rate group test) but would be in any Average Benefits Test.

Any catchup contributions are completely ignored in any of these tests.

Posted

Slight clarification. Current year catchups are excluded from all tests. Prior year catchups are included (with earnings) to the extent one is using accrued to date testing.

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