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Posted

A stand-alone DB plan has multiple formulas for varying job classifications. Example, 7%, 2% and no accrual rate (0%) for some job classifications.

Obviously this is not a design based safe-harbor formula. The question is whether the general test under 401(a)(4) is the only testing method available or is there an alternate approach by testing each benefit accrual rate separately under 410(b) via "restructuring" by testing each formula separately for 410(b) and if it passes 410(b) on that basis does that obliviate the need for the 401(a)(4) general test ?

Posted

I think you can do as you suggest. As long as each component passes 410(b) then they would be uniform and pass a(4).

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