Rate group testing

[Guest]

In a cross tested plan with a 401(k) feature, the salary deferrals must be included when determining whether or not the plan satisfies the average benefits test. Questions: (1)A company has a SARSEP and during 1999 wants to start a Safe Harbor 401(k)(3% QNEC, no match). Is the SARSEP considered an existing p/s plan? (2)Assumung the answer to (1) is no, must the deferrals to the SARSEP prior to the effective date of the 401(k) plan be included in the average benefit test?

[Guest]

as a SARSEP is not a 401(a) plan, there is no nondiscrim testing, so I assume you do not use any of the SARSEP deferrals in the avg ben test if you have another cross tested plan as well.