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If a plan sponsor adopts a new DB plan in 2010 that provides for 5 years past service credit and that the plan is being aggregated with a profit sharing plan for 401a4 using the annual accrual method, are the entire 6 years of DB accruals included in the first year's test or just the 2010 accrual? For example, would a participant benefiting under a 2% per year of credited service formula with 10+ years of service be included in the test with a 12% DB normal accrual rate?

If the previous 5 years are not included in the test, are they required to be tested in any other way?

Thanks in advance.

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