"If a plan is restructured into component plans, may each component plan be tested on a different basis (e.g., one component tested on a benefits basis [cross-tested] and the other component tested on an allocation basis)? ... If one component satisfies nondiscrimination on a benefits basis (cross-tested) and another component satisfied nondiscrimination on an allocation basis, may the plan limit the minimum gateway requirements to the cross-tested component? ... May a plan use restructuring for purposes of the minimum participation requirements (DB plans)?" [Editor's note: see also SunGard's later-issued article on this subject.]

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