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401a4 testing age for a combo plan

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Double checking the following for a combo plan design as haven't seen for a while:

Existing DC plan with NRA 65 only

Planning to add a DB plan for 2023 with NRA 65/5 YOP

Owner is age 64.

Under DC plan NRA is 65

Under proposed DB plan NRA is 68

What is the testing age for combo plan?

The system is taking the AB and actuarially reducing to age 65 and testing it. I find this a bit skewed and favorable to owner as:

  • less years to project
  • lower AB for testing

What am I missing here?


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