With regards to 1.401(a)(4)-8(b)(1)(iv)(D)(2), it refers to "allocation rates based on age". Does this apply to plans with allocation rates based on points representing age plus service?? Thanks.

no because, for example, 2 people with the same age could have different years of service and therefore different contribution % amounts, thus you wouldnt have smoothly increasing bands.

what few points plans I have looked at would pass the 1/3 rules under the gateway minimum so I doubt this would be an issue anyway.

the normal testing for a points plan, at least as a first steo is testing on an allocation basis and running something similar to the avg ben % test on the ps contributions (and using 100% instead of 70%)