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Does Elective Deferrals under Sec. 408(k)(6) (SARSAP) added back to the elective deferral under Sec. 401(k) Plan when performing the ADP test?

Background information:

Reviewing a copy of the 2015 Form W-3 totals (under the summary of W-2 Data) for a new prospect, I have learned that there are both Code D (with 35 employee count) and Code F (with 12 employee count) for box 12.

It appears that this new prospect established a new 401(k) plan in 2015 when the number of eligible employee goes over 25. For part of the 2015 plan year; however, this new prospect some employees deferred under the 408(k)(6).

From my reading of ERISA outline book Chapter 11 that goes over 401(k) vs. SARSEPs, the deferrals in both plan needs to be added to make sure the total doesn't go over the 402(g) limit. Also, ADP test for the two type of plan is very different.

But I’m still not 100% sure whether I should use the total of the two different plan deferrals for my ADP test as I should do for 402(g) limit test.

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