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Posted

Plan has a NCP PS allocation with each in participant in their own group.  

For 2023, the client has made 3 groups.  Group 1 & 2 = 3%  Group 3= 0%

Do I need to run a 401(a)(4) General Test or if they pass coverage, am I good?

Posted

So the coverage ratio is 70% or more, and the contributions are a uniform 3% (a safe harbor uniform percentage of compensation) for those who do get them? 

That'd be fine.

Posted

Strictly speaking, you only get a free pass on general testing if the plan is a design-based safe harbor, meaning that the safe harbor allocation formula is required in the plan document. If the plan document says each participant is in their own group, then you do not have a safe harbor allocation formula and you need to run the general test. However, if every participant who benefits is getting the same allocation rate, then the test should pass easily on allocation rates, no cross-testing required.

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.
corey@pppc.co

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