DB/DC Plans

[David]

An employer sponsors a DB plan with a non-integrated safe-harbor formula and a super-integrated PS plan. Both plans cover all ee's of the employer and independently meet the 70% 410(B) test. When doing the cross-testing on the PS plan, do the DB accruals need to be included in the 401(a)(4) calculations?

[richard]

As long as the PS plan doesn't "need" the DB plan, you can ignore the DB accruals for 401(a)(4) purposes. There is a section in the 401(a)(4) regs that permit separate testing and calculations of DB and DC plans.

Alternatively, you could choose to aggregate both plans and use both the DB accruals converted to contributions plus the DC contributions (or DC contributions converted to accruals plus DB accruals), which might actually be better for your client (although more work for you).