Controlled Group - Multiple Plans - Coverage Testing

Employer has several USA Divisions and there are 3 401(k) Plans:

- Plan A by other TPA - Age 21 and 6 months, with monthly entry dates, Safe Harbor Match

- Two Plans by us as TPA - Plan B has entry on the date of hire and is a Safe Harbor Match. Plan C has a 2-month wait, with monthly entry dates and discretionary match.

Plan C is a smaller Plan and will not pass coverage on its own. However, this Plan was effective 01/01/2017 but they did not hire anyone until mid-November 2017 (i.e. no contributions as no one was eligible).

We cannot use the RPT for coverage - correct?

If not, I believe we can use the ABT - correct?

I couldn't figure out what you meant by RPT, but I guess you mean ratio % test. there is no reason you can't use that test that I can think of.

you can't aggregate a safe harbor with a non-safe harbor - but other than that permissive aggregation rules should apply.

there is one average benefits percentage test consisting of all contributions (unless you test otherwise excludables separately and then of course there would be 2 average benefit percentage tests.) but that is just the percentage test, not the average benefits test itself.

Thank you, Tom. Yes - Ratio % Test.