BRF Testing for QJSA provisions/401(k) MPP merger

[KJohnson]

I know where you had a money purchase pension plan merger, the PPD document allows you to subject the entire account (including non money purchase amounts) to the QJSA provisions for those who have money purchase amounts remaining and exempt the entire account from the QJSA provisions for those that do not.

This makes sense from an administration point of view because it is easier than simply making the money purchase portion only subject to the QJSA provisions. In that instance you can have a single participant whose distribution falls under both the QJSA and non-QJSA rules.

My question is whether you have to do BRF testing with regard to offering some participants an annuity option on their non-money purchase pension amounts while not offering it to other participants.