Controlled Group - One Plan

[PFranckowiak]

Plan covers several companies in a controlled group.

One of the companies has been hit by the economy.

Plan is currently on Cobel prototype. Deferral and Discretionary Match Only. (In process of EGTRRA restatement)

All the companies have been putting in the same match amount.

Company B wants to reduce or eliminate their match.

1. With the prototype doc can you have different employers having a different match. If no - VS or ID?

2. What testing is required besides the ACP? If they reduce Match to zero, I might have coverage issue, but is their anything else I need to worry about?

3. Could each of the companies have a different match?

Appreciate any input on what questions etc I might be missing.

Pat

[Laura Harrington]

Plan covers several companies in a controlled group.

One of the companies has been hit by the economy.

Plan is currently on Cobel prototype. Deferral and Discretionary Match Only. (In process of EGTRRA restatement)

All the companies have been putting in the same match amount.

Company B wants to reduce or eliminate their match.

1. With the prototype doc can you have different employers having a different match. If no - VS or ID?

2. What testing is required besides the ACP? If they reduce Match to zero, I might have coverage issue, but is their anything else I need to worry about?

3. Could each of the companies have a different match?

Appreciate any input on what questions etc I might be missing.

Pat

1. The GUST and EGTRRA prototypes we use allow for this, although they are not Corbel documents. The wording you are looking for will be something along the lines of allocating the contributions to each participating employer separately. In our GUST prototype it was an option in the adoption agreement in the contribution sections and in our EGTRRA prototype it is on the the Participating Employer adoption page.

2. In addition to ACP testing you will need to demonstrate that each rate of match is available on a nondiscriminatory basis. This is sometimes called Benefits, Rights and Features testing.

3. Yes, each company could have different match formula assuming you can amend the document to allow for it and the benefits, rights and features testing is satisfied.