What is my testing age for combo plan?

[Jakyasar]

Hi

This may have been discussed before but cannot remember/locate and having a slow day today (mentally and smoke is coming out my head). I have been trying to find material for the following situation.

Existing DC plan, current participants are past age 65 (NRA)

Starting a new DB plan for 2025 which will have NRA 65 with 5 YOP i.e. if someone is currently age 67, NRA is 72.

I have 3 participants all past 65 with different ages. Currently 66, 67 and 68. For DB, NRA would be 71, 72 and 73 (they are all past NRA under DC).

What ages am I testing them for combined plans?

[John Feldt ERPA CPC QPA]

Take a look at Treasury Regulation section 1.401(a)(4)-12 and see if that helps. Keep in mind that in the reg, the term “plan” is actually the tested “plan”, which is the combined employer DC contributions and DB benefit amounts (other than match) from both the CB and the 401(k).