A plan that is not covered by the PBGC can make a maximum deductible contribution to the DB plan and a 6% of comp contribution to DC plan.

However, if the DB plan is covered by the PBGC the combined plan limit does not apply and then the employer can contribute up to 25% to the DC plan.

Can an employer that would be eligible for the PBGC coverage exemption, choose to be covered by PBGC in order to obtain the higher DC plan deduction limit?

Eg prof employer w less than 25 participants.

Thanks.

Can't locate documentation now, but I recall the PBGC saying (emphatically) that no plan can elect to be covered.

To my knowledge the employer cannot elect to be covered by the PBGC. They either are or are not.

If near the 25 limit, they could get a couple more folks to get over 25. I think they are then covered from that point even if they drop below 25.

Agreed. PBGC coverage is not an election, you either are or you're not.