I feel more comfortable if the DB/DC plans have to have the same trust name in order to commingle plan assets. I know there are TPAs out there commingle assets for the two plans have different name and trust IDs. What do you think? If the plans have different trust names and IDs, can a simple plan amendment solve the issue? Is there any other administration issues? Where are rules in this area?

Since no one else has responded to this directly, maybe some thoughts on a slightly different situation will help.

Years ago when I was administering Money Purchase Pension and 401(k) combinations, people wanted to put them together when they went to a platform like John Hancock or Transamerica. Commingling was a huge benefit in pricing. Since then I have had 2 of these combination plans audited by the IRS and they showed no concern at all.

They were both DC Plans, but they did have different names and EINs.

Hope this helps.