Offset Plans

[mphs77]

Excuse me but is has been a while since I worked on an Offset Arrangement (DB Plan offset by contributions to a DC Plan).

In a DB Plan where there are different benefit formulas for different groups, will I need to pass 401(a)(4) for the DB Plan alone before I apply the offset? Or do I only have to pass 401(a)(4) in a combined arrangement with the DC after the offset is applied?

Thanks for all your help.

[Blinky the 3-eyed Fish]

How about neither. First, you definitely test the DB plan after applying the offset. That is part of the DB formula and thus must be considered. Secondly, you can permissively aggregate the plans for coverage and nondiscrimination, but that is an option. Most general tested DB offset plans will need permissive aggregation to pass.