What limits are combined when Employer maintains 401k/PS and Cash Balance Plan

[jkharvey]

I'm drawing a blank here, sorry. The employer has a PS/401k plan and CB plan. The plans are aggregated for nondiscrimination and 404 deduciton, but totally separate 415 limits. Is that correct?

I keep wanting to say 415 has to be combined, but I think I'm bringing in the old rules...really old rules.

[MWeddell]

Code Section 415(e) used to include limits that affected both DB and DC plans, but it was repealed about 14 years ago. So, yes, the 415 rules are separate for the two plans you have.

Whether the plans are aggregated for nondiscrimination testing purposes depends. They may be aggregated or may be tested separately.

[John Feldt ERPA CPC QPA]

And if the DB plan is subject to the PBGC coverage requirements, the combined plan 404 deduction limit under 404(a)(7) also goes away.