I have a client who has a X-tested PS plan, the two key employees are fairly young (41,35) so this may not be the best scenario for this, but we are looking at the possibility of adding a DB plan on top of the PS plan. My question has to with comp for testing . The PS plan uses compensation while a participant for allocation purposes. I know i can use participation comp for testing the PS plan. If i add a DB plan with standard 21,1yr elig, 1/1, 7/1 entry dates, can i use the same participation comp for testing the DB accruals???

Not sure I understand what you mean by "testing the accruals". What kind of DB plan? safe harbor design? cross-tested? etc.

If it was a safe harbor design would i have to test the accruals?? Let's say it's not a safe harbor design.

The answer either way is yes, except for top heavy purposes, where you have a minimum based upon 415 comp.

Thanks. Now let me ask you this. If the DB plan is a non Safe harbor formula, and i test the DB plan on an allocation basis and the PS plan on a benefits basis, how is the average benefits test performed??

Either way; one way or the other.

But, dmb, I can't imagine a situation where you would want to cross test both an entire db and an entire dc plan. Unless you are restructuring into component plans, one usually works much better than the other, and it's usually on a benefit basis.