When setting up a New Comparability PS plan using DBRAs to replace a DB plan, and rather than meet the Broadly AVaible GAteway, we will meet the 5% or 1/3 gateway. Can one group receive an allocation of "the greater of the DBRA or 5% of comp" or would each participant receiving the DBRA need to be their own group?? I'm not sure if my question makes sense, but any help would be appreciated. Thanks.

How are you allocating the DBRA? Since the plan requires a definite allocation method, either you already have everyone in a separate group, or you have many receiving the same % or pay or flat $ amount.

Anyway, do the DBRA and then top off anyone not getting the 5% / 1/3 gateway.

Thanks for the response. I'm not sure how we will be providing the DBRA yet, but i guess another question is can we have all or some of the participants who recieve the DBRA in one group since the replacement allocation for one particpant may be a different allocation as a percentage of comp than another particpant? Thanks.

huH? (that is Huh spelled backwards)

You cannot have employees receiving different allocations (other than Gateway) and be in the same group.