The history of cross-testing

[Guest Matt Hutcheson]

Looking for history of cross-tested plans. i.e. TRA 86 to final 401(a)(4) regs., information relating to the IRS's desire to disallow them early on etc.

Thanks

[Lorraine Dorsa]

The best place to look for information regarding the history of 401(a)(4) and cross-testing would be in the course material for the seminars sponsored ASPA or Corbel or PPD or other entities from about 1989 to date. Many people keep their course materials for several years so you should be able to find this material.

Another alternative is CCH or one of the other services. I remember seeing a good historical summary of just this issue in CCH a few years ago when I was researching a talk I was giving on non-discrimination testing.

[Guest D_NITSCHE]

The technical justification for cross-testing is embodied in the 401(a)(4) regs. my recollection is that a consultant in the midwest originally developed a spreadsheet approach to illustrate how these plan designs would pass (a)(4).Then the Kravitz company on the west coast got hold of the spreadsheet ideas & started marketing these plans in a big way. This isn't alot of history but I hope it adds a little.