401a4 testing - accrued-to-date - combo plan

[Jakyasar]

Hi

A bit confusing myself with a scenario I have not seen before.

Defined benefit and profit sharing combo.

DB started 2015(HCE only) and PS started 2019. One non-HCE was already in the DB plan for 2018 - year of participation. Another non-HCE is only in the PS plan i.e. excluded for DB categorically. All 3 are participants in the PS plan effective 1/1/2019.

DB was amended for HCE only during 2020 using A+B method (A x% of average comp for YOS starting 1/1/2020) and B is AB as of 12/31/2019 without wearaway - standard design.

I usually use annual method but for 2020 wanted to look into accrued-to-date method. Assume all data is correct for all past years i.e. I have the correct salary history and the PS plan assets are all correct.

Are there issues I need to watch out for the 401a4 testing?

Thanks

[Jakyasar]

Any takers?

[Jakyasar]

I guess no takers.

[Effen]

I don't know the answer to your direct question, but my initial concern was 1.401(a)(4)-5

 Plan amendments and plan terminations.

(a) (2) Facts-and-circumstances determination. Whether the timing of a plan amendment or series of plan amendments has the effect of discriminating significantly in favor of HCEs or former HCEs is determined at the time the plan amendment first becomes effective for purposes of section 401(a), based on all of the relevant facts and circumstances

If the amendment benefited the HCE, you should make sure the timing of the amendment was not discriminatory.