Multiple Matching Formulas

[LANDO]

I have a plan that wants to use a fixed match for "Administrative and Hourly" employees (50% on 4%), and a discretionary match for "Patternmakers". Any HCE's would be in the Administrative and Hourly group, and the Patternmakers would have no HCEs.

I assume if the fixed match for Administrative and Hourly employees exceeds the match made for the Patternmakers we would have to test for Benefit, Rights or Features (BRF) issues since the rate of match available to an HCE would exceed the match available for a NHCE. However, if the sponsor decided not to make any match for the Patternmakers in a plan year, would that simply be a coverage issue, or would the rate of match for the Patternmakers be considered to be zero and, therefore, BRF testing comes back into play?

Clearly, excluding certain groups from receipt of match completely is just a coverage and ACP testing issue, and I guess I am struggling to see the differnce between saying the Patternmakers are excluded from the match, and saying the Patternmakers are eligible for a match, but the matching rate is zero. That leads me to the conclusion that BRF testing wouldn't apply in years where the discretionary match for Patternmakers is zero.

Can someone please clarify when Benefits Rights and Features testing would apply to this situation?

Thanks

LANDO

[Lou S.]

You have different rates of match for different groups of ees than you have BRF testing.