DC/DB Combo - Gateway

I again apologize for all the questions, as I'm trying to learn and help out in my office.

When we have a DC/DB combo plan, the 7.5% Gateway (I know it can be less than this, but generally is viewed as the "Safe Harbor" comes exclusively into the DC Plan correct?  I just wanted to make sure.

Thanks!

No. To satisfy the combo gateway, the aggregate normal allocation rate (ANAR) has to be at least 7.5% for all NHCEs if the ANAR for any HCE is greater than 35%. Aggregate means the sum of the DB and DC allocation rates. You convert the annual accrual in the DB plan into an allocation using the interest rate and mortality selected for testing. For NHCEs getting an accrual in the DB plan, you can also substitute the average DB allocation rate for all NHCEs instead of using each individual's allocation rate; this avoids having different PS allocation rates needed for every employee to satisfy the gateway.

A gate-way of 7.5% of 415(c)(3) compensation to all NHCEs is not a "safe-harbor" but I think I'd have a hard time coming up with an example where a 7.5% allocation didn't pass the gate-way part of the general test.