FAQ 642: ADP--Borrowing-Why does it borrow the same % from HCEs and non-HCEs?

Problem:

Please take a look at the attached result for an ACP test. I have indicated my questions on the summary page. Could you explain why ASC is programmed to borrow from the HCE ADP and put it in the HCE ACP at the same time as borrowing from the NHCEs? If it did not borrow from the HCE ADP and put it in the ACP, the test would pass, which is the result we feel we should be getting. Thanks for your input.


Solution:

The ADP test must pass both before and after you borrow from it. If you borrowed only from non-HCEs to pass the ACP test, then the ADP test percents remaining in the ADP would fail.