Part 1:

I would like to check my interpretation of Testing Age in 1.401(a)(4)-12.

Combining plans for 410(b) and 401(a)(4).
DB Plan NRA = Later 62 or 5 YOP (NRD is first of mo. following)
DC Plan NRA = 65 (NRD is first of mo. following)

No EE is at or past either plan's NRA. No EE comes under the 5 YOP NRA provision.

EE1 is in the DB Plan Only
EE2 is in the DC Plan Only
EE3 is in both plans.

Testing Age:

EE1 = 65
EE2 = 65
EE3 = 65

Agree/Disagree????

Part 2:

What if the NRD in the DC plan is the last day of the plan year NRA is attained (the DB NRD is first of month following NRA). Therefore, in the DC plan, some particpants actually retire at age 66 based on age nearest birthday. Would that change anything? The regs only use the term "normal retirement age" not "normal retirement date". I can add that my software vendor uses age nearest at NRD. If age nearest at NRD is applicable, would everyone's testing age be 66 or just those that are actually 66 at NRD (the rest would have an age 65 testing age)?