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Posted

Can a plan run the ADP test on a disaggregated basis and the ACP test on an aggregated basis or do these have to be run the same way?  In this example, I know we would have to disaggregate the 410(b) test for the deferrals and would aggregate the 410(b) test for the match contributions.  This is a single employer plan and there are no controlled group members.  Thank you

Posted

What kind of disaggregation are we talking about? Otherwise excludable employees?

I'm going to say yes, your testing elections for ADP and ACP would typically be independent of each other. There might be some cases where one would depend on the other, like if you have QMACs you are counting in the ADP test or shifting deferrals to the ACP test; I would have to look up the details of those rules to be sure.

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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