Compensation for ABT - combo ESOP and k plan

[cpc0506]

We have a client who sponsors both an ESOP and a 401k plan.  ESOP owns 100% of company.

Client is looking to split the 401k plan into 2 separate plans - one a safe harbor plan and one a tested plan.  We know that we will have to run the ABT for the plans as the coverage test will not pass the 70% threshold.

Right now the ESOP and the 401k plan use different definitions of compensation.  It seems that the same definition of compensation must be used to run the ABT.  Can the plans still apply 2 different definitions of compensation for allocation  purposes and just use the same definition for testing purposes?  Or do both documents need to specify the same definition of compensation?  The ESOP currently excluded commissions in excess of $150,000 (and yes, there are a handful of employees for whom this exclusion does apply.)

[Mike Preston]

The testing comp doesn't need to be either allocation comp.

[cpc0506]

59 minutes ago, Mike Preston said:

The testing comp doesn't need to be either allocation comp.

Mike,  are you saying that just so long as you use the same definition of compensation when running the combined ABT, that is all that matters and it does not even have to be one of the definitions of compensation used in either plan?

[Mike Preston]

I am.