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Government Pick Up Plans and 415 Testing


Guest DKE

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A government entity has three plans, a DB, 401(a) DC pick up, and 457(b). My understanding is the contributions "picked up" in the 401(a) DC plan must be tested under 415(b). Would the employer contributions in the DB and 401(a) DC plan be aggregated for for 415 testing? I believe the plans would be combined for this purpose, but I cannot locate any resources that specifically state this is the case.

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  • 1 year later...

Why would contributions (picked up or otherwise) to a DC plan be tested under 415(b)? That section applies only to DB plans.

There is a special rule that employee contributions to a DB plan that are assigned to a separate account are separately tested under 415© (and the benefit generated by them is excluded from the benefit subject to the 415(b) limits). But there is no rule that would make employer contributions (picked up or otherwise) to a DC plan subject to the 415(b) limit.

Employee benefits legal resource site

The opinions of my postings are my own and do not necessarily represent my law firm's position, strategies, or opinions. The contents of my postings are offered for informational purposes only and should not be construed as legal advice. A visit to this board or an exchange of information through this board does not create an attorney-client relationship. You should consult directly with an attorney for individual advice regarding your particular situation. I am not your lawyer under any circumstances.

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  • 4 weeks later...

Yes, it does.

Employee benefits legal resource site

The opinions of my postings are my own and do not necessarily represent my law firm's position, strategies, or opinions. The contents of my postings are offered for informational purposes only and should not be construed as legal advice. A visit to this board or an exchange of information through this board does not create an attorney-client relationship. You should consult directly with an attorney for individual advice regarding your particular situation. I am not your lawyer under any circumstances.

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