Incidental Death Benefit in Combo Plan

[AndyH]

Looking at a proposal for a CB/PS combo with life insurance. Owner gets 70% of pay in CB, employees get 2%. Maximum insured death benefit provided in the CB.

Is there a way to modify this to satisfy both the incidental death benefit rules and the Benefits Rights and Features requirement with the insurance this skewed?

[John Feldt ERPA CPC QPA]

As you know, the "benefit" being tested under 401(a)(4) is the combination of the benefits from both plans. I would think the incidental benefit would need to be based on that "benefit", which could easily exceed the maximum allowable life insurance benefit that the DB plan can actually provide to the NHCEs in the DB plan. Who wants life insurance in a combo design? Is Ned Ryerson involved?

[AndyH]

Double bingo. Ned's been on a years long yachting excursion it seems. Thanks.