Cross testing DC plan for sponsor with DB plan

[AndyH]

Is there any way around having to add the DB employee benefit percentages to the DC EBARS for purposes of the average benefits percentage test component of the general test?

Assuming the DC plan does not have all rate groups at 70%, does the DB need to be added?

It appears to me that the DB does not needed to be added if the DC is tested on a contributions basis (1.410(B)-5(e)(3)), but must be added if the DC is cross tested. Correct?

To any of the DB people out there: Isn't this true with a DB general test as well-i.e. if the DB is tested on a benefits basis, the DC can be ignored?

[Guest PAUL DUGAN]

For the 3rd time today I agree with you. The 2 plans do not have to be added together unless one of the plans is cross tested.

[Guest FredReilly]

Since you indicate that the EBR's do not pass the test on the basis of the ratio percentage test, how can you get around the requirement to include all benefits under all plans for purposes of the Average Benefits Test?

[AndyH]

Fred, there is an exception in the regs in the cite I noted above when a plan is general tested, but not cross tested. I'm not sure this is common knowledge.

Paul, thanks for the quick feedback.