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Posted

Three employers are members of a controlled group (A, B, C) and they each sponsor a 401(k) plan with different features.  Each plan passes coverage separately - but barely.

Let's say an employee transfers mid-year from Employer/Plan A to Employer/Plan C, is that employee considered in Plan A only or Plan C only or both plans for coverage purposes?

Thank you for any insights and references!

PensionPro, CPC, TGPC

Posted

If an employee is eligible to make a deferral in a plan they are considering benefiting under that plan for purposes of 410(b), so in your case it appears to be both plans.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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