Combo plans - testing age

[Jakyasar]

Hi

Existing DC plan with NRA 65 only. Plan effective 1/1/2018.

Participant DOB 1/1/1946, DOH 1/1/2011, DOP 1/1/2018 thus NRA attained on 1/1/2018.

Looking to add a CB with NRA 65 and 5 YOP

Participant attainted age at val date (EOY) 75 with NRA 79. This is for the CB plan.

When testing for combo plans, the system used 75 as the testing age.

Is this correct under 401a4-12?

Thanks

[Nate S]

Yes, it would be tested at the earliest applicable age which generates the MVAR.