I have a plan that is failing the ADP test. The client wants to know the refund amount. I was about to calculate the refund and the earnings, but after a discussion with a colleague, I now have the following question: Are the earnings to be calculated on the 401(k) monies only or each particpants total account balance including other money types. My opinion is to use only the 401(k) money type. My colleague think it should be total account balance. I checked the ERISA outline (Good Old Chapter 11) and it says that there is no definite answer, just be consistent. I still do not know which method to use.

Any help would be greatly appreciated.

401(k) monies only.

My hand calculations and our software calculations are the same to the penny.

Thanks.