Testing Requirements for CB/PS Combo Plan with Different Eligibility Dates

I'm running into a problem and just looking for some insight.  We have a Plan that has immediate eligibility for the 401(k)/Safe Harbor Match, but we are looking to do 21 & 1 year for the Profit Sharing & Cash Balance portions.

I know the Safe Harbor Match (for everyone) gets factored into the 6% maximum deductible contribution for the employer contributions.

That said, for the people who are eligible for the 401(k)/Safe Harbor, are they factored into the rest of the testing for the PS/CB?  For instance, when we are doing the rate group testing are those people factored in?  Or do we only test for the people who are eligible for the Cash Balance Benefit?

I hope that makes sense.  Just trying to make sure I have all of my bases covered

Those not eligible by age/service for PS and CB would not be included in your rate group testing.

Good luck if you have to navigate a 6% DC limit to avoid combined plan deduction limit with a SHM.

4 minutes ago, CuseFan said:

Those not eligible by age/service for PS and CB would not be included in your rate group testing.

Good luck if you have to navigate a 6% DC limit to avoid combined plan deduction limit with a SHM.

Thanks.  That plan was in place already, obviously the recommendation is to go to a 3% Safe Harbor but they may not want to take it away

15 minutes ago, CuseFan said:

Those not eligible by age/service for PS and CB would not be included in your rate group testing.

Good luck if you have to navigate a 6% DC limit to avoid combined plan deduction limit with a SHM.

We'd use everyone's salary for the 6% cap, correct?  So technically everyone's salary is eligible, so it's 6% of all of the eligible compensation for the Safe Harbor + Profit Sharing limit?  I just want to make sure I'm thinking it through correctly

Aggregate compensation of DC participants, so I would think so.

Even if they do not defer and get a SHM?

I meant for the new participants who are not eligible for PS allocation.