Plan is effective 1/1/99 but deferrals don't commence until 12/1/99 -

[Kathy]

I think the first place to check is the plan document. How does it define compensation for testing?

[Hoard1]

If a Plan is effective 1/1/99 but deferrals commence 12/01/99 can the testing period for ADP and ACP contributions be 12/01/99 to 12/31/99. Thanks Cites would be great.

[MWeddell]

Besides checking the plan document, also look at Treas. Reg. 1.401(k)-1(g)(2)(i)(fourth sentence). You may limit the compensation for all eligible employees to just the amount earned during the portion of the plan year when each employee was eligible to make a cash or deferred eleciton.