401a4 Testing with DB/DC combo

[emmetttrudy]

If a plan sponsor has a DB Plan with a flat beneit x% of Average Comp for all participants (HCEs and NHCEs), and they also have a 401k PSP, can the 401k PSP be tested on its own for 401a4 since the DB formula is a safe harbor? This is a PBGC Plan so no combined deduction limits to worry about.

[SoCalActuary]

may be a safe harbor if you require 25 years for full benefit.

if the db plan passed on its own, then you would be able to test all other plans without it.

However, if those other plans depend on the db to pass, then you have aggregated plans.

[AndyH]

If a plan sponsor has a DB Plan with a flat beneit x% of Average Comp for all participants (HCEs and NHCEs), and they also have a 401k PSP, can the 401k PSP be tested on its own for 401a4 since the DB formula is a safe harbor? This is a PBGC Plan so no combined deduction limits to worry about.

I don't think that enough information was provided.

Is each plan a safe harbor or not?

If yes, done.

If no, can the non-safe harbor plan pass 401(a)(4) on it's own without permissive aggregation?

If yes, you may still need to pull the other plan into the average benefit test if all the rate groups are not at 70%.

If no, then obviously you must aggregate.