Up until recently, I was self-employed, and maxed out the qualified plan contributions (401k deferrals, safe harbor, profit sharing, and Cash balance).
My pension guys told me I could not do that as
While after-tax contributions seem attractive to those wishing to save as much as possible in an employer sponsored plan, any after tax contributions are subject to what is called ACP testing (Actual Contribution Percentage) which compares the average percentage of the contributions of the Highly Compensated Employees (HCEs) against the average percentage of the Non Highly Compensated Employees (NHCEs). Since it is unusual for any NHCEs to make after tax contributions, the testing is highly likely to fail which would then require refunds to those who contributed to the after tax account.”
The plan is getting shut down, and I'm currently enrolled in a new employer's plan, which allows after tax contributions (and I believe in-service rollovers).
For 2022, I have contributed $15K in profit sharing and $432K in CB contributions to the old plan, and $19.5K to the new one.
Am I correct in assuming I can do after-tax contributions to new plan without affecting the old one?