I am trying to prepare a DB & PS combo where no participant participates in both plans. The DB is a safe harbor formula, the PS is cross-tested. By testing both plans on an aggregate basis, both the midpoint rate group test and the average benefits test pass. Does the PS plan still need to pass the 70% coverage test?? Thanks.

If you are aggregating the two for a(4) testing, then you are aggregating them for coverage. It sounds like 100% are in one plan or another, in which case you pass the ratio percentage test by 100% on a combined plan basis.

Watchout for the DB/DC combo gateway requirements WRT a(4) testing.

Thanks. I'm glad you mentioned the combo gateway. I have a couple of participants that worked less than 1000 hours and receive only TH minimum. I had them getting 5%, i guess they have to get 7.5% since the highest HCE alloc is greater than 37.5%. Thanks again.

37.5% is not the cutoff to require the NHCE's to receive the 7.5% minimum gateway. It is 35.000000000000000000000000000000000000000000000000000000000000000000001%

Neither my brain nor my calculator has that kind of precision!