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Permissive aggregation for coverage/ACP testing

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Suppose you have two non-governmental tax exempt employers, each of whom sponsors a 403(b) plan with, for all practical purposes, identical provisions. Both are calendar year plans. Are there any particular problems with permissively aggregating them for coverage and ACP testing, if one fails, but permissive aggregation would allow them to pass? I'm not seeing any, but perhaps I'm missing something.

It occurs to me that the original post left out the fact that they are a controlled group - a rather important piece of information!


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