DB/DC Gateway Testing

[Young Curmudgeon]

This is an ongoing plan for which we have always satisfied the gateway test with a 6% DC contribution. This year, the owner's compensation went from 250k down to 35k.

The DB benefit is based on a historical high 3 compensation. Our system is throwing a 197% combined benefit rate as it's compariing the current year additional accrued benefit (based on 246K average) to the current year $35k compensation.

I understand the gateway test has to be run using 415©(3) compenstion, but does it really have to compare a high 3 average benefit to a single year's compensation?

[shERPA]

Test on average comp?

[Young Curmudgeon]

_{I would like to, but can we do that and still satisfy the requirement to us 415©(3) compensation. Our basic definition does, so would our average compensation satisfy it?}