100+ Free CPC Practice Questions

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A plan loaned $250,000 of plan assets to the employer (a party in interest) at a below-market interest rate of 1%. Why is this a prohibited transaction even though the loan is to be repaid in full?

Only because the loan exceeds 50% of plan assets, violating §407 employer security limits

Only because the loan exceeds $250,000; loans below that threshold are exempt under §408(b)(1)

Only because the interest rate is below market; an arms-length rate would cure the violation

ERISA §406(a)(1)(B) and §406(a)(1)(D) treat any extension of credit between a plan and a party in interest as a per se prohibited transaction, regardless of repayment terms or interest rate; only a statutory or class exemption can cure it

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2026 Statistics

Key Facts: CPC Exam

100

Practice Questions

OpenExamPrep CPC bank

$455

Standalone Exam Fee

ASPPA 2026 fee schedule

$895

Education + Exam Bundle

ASPPA 2026 fee schedule

70%

Passing Score

ASPPA CPC Candidate Handbook

QKA+QKC+QPA

Required Prerequisites

ASPPA CPC eligibility rules

120-200 hrs

Typical Study Time

Candidate community consensus

CPC is the senior ASPPA consulting credential, requiring prior completion of QKA + QKC + QPA. The 2026 fee is $455 standalone or $895 for the education + exam bundle. Coverage spans complex plan design (15%), cross-testing (12%), terminations/mergers/spinoffs (12%), EPCRS corrections (10%), prohibited transactions (10%), QRP (10%), fiduciary litigation risk (10%), SECURE Act consulting (10%), consulting strategy (8%), and MEPs/PEPs (3%). The exam has historically used essay/case format; the practice bank here uses 4-option multiple choice for repetitive drilling.

Sample CPC Practice Questions

Try these sample questions to test your CPC exam readiness. Each question includes a detailed explanation. Start the interactive quiz above for the full 100+ question experience with AI tutoring.

1A consultant is advising a 200-employee employer that wants a single retirement program covering employees of two unrelated subsidiaries with different payroll providers. Which arrangement BEST satisfies the client's goal while reducing administrative burden under SECURE Act §101 simplification?

A.Adopt a Pooled Employer Plan (PEP) sponsored by a registered pooled plan provider (PPP) under ERISA §3(44)

B.Establish two separate single-employer 401(k) plans linked by a master trust

C.Use a SIMPLE IRA at each subsidiary with cross-subsidization

D.File a Form 5500 Direct Filing Entity (DFE) election

Explanation: A PEP, authorized by SECURE Act §101 and ERISA §3(43)/(44), allows otherwise unrelated employers to participate in one plan sponsored by a Pooled Plan Provider. The PPP becomes the named fiduciary and §3(16) administrator, eliminating the prior 'commonality' requirement that limited traditional MEPs.

2Under the SECURE Act 'one bad apple' relief codified at IRC §413(e), what happens to a participating employer in a MEP that fails to satisfy a qualification requirement after the employer refuses to take corrective action?

A.Only the noncompliant employer's portion of plan assets is spun off and treated as a separate (and potentially disqualified) plan, leaving the MEP's qualified status intact

B.The entire MEP is disqualified retroactively to the year of the failure

C.The MEP loses its tax-exempt trust status only for the noncompliant year

D.Each participating employer must pay its pro-rata share of the §4971 excise tax

Explanation: IRC §413(e), added by SECURE Act §101, eliminated the unified plan rule. The MEP's qualified status is preserved; the noncompliant employer's assets and liabilities are spun off to a separate plan that bears the qualification consequences, provided the MEP follows the prescribed spinoff procedures.

3A PEP's Pooled Plan Provider (PPP) wants to charge participating employers an asset-based administrative fee paid from plan assets. Which fiduciary requirement is MOST directly implicated?

A.The PPP must acknowledge ERISA §3(16) and §3(21) fiduciary status and ensure the fee is reasonable under ERISA §408(b)(2) and PTE 2020-02 disclosures

B.The fee must be approved by a majority vote of all participating employers each plan year

C.The PPP must obtain a private letter ruling under §401(a)(35) before charging the fee

D.The fee must be capped at 50 basis points by DOL regulation

Explanation: ERISA §3(44) requires the PPP to acknowledge fiduciary status. Fees paid from plan assets must satisfy the §408(b)(2) reasonable-arrangement exemption; if conflicted investment advice is involved, PTE 2020-02 imposts additional disclosure and best-interest requirements.

4Acme Corp (calendar-year 401(k)) wants to terminate its plan effective 9/30/2026 because it is being acquired. Under Rev. Rul. 89-87, what is the LATEST date for distributions to begin so that the plan can be treated as terminated for §401(k)(10) purposes?

A.Distributions must generally be made 'as soon as administratively feasible,' typically within 12 months of the termination date

B.Distributions must be completed by the close of the termination plan year

C.Distributions must be completed within 60 days of the termination resolution

D.Distributions must be completed before the §401(k)(10) successor-plan 12-month window closes

Explanation: Rev. Rul. 89-87 treats a plan as terminated only if assets are distributed 'as soon as administratively feasible,' generally interpreted as within 12 months of the formal termination date. The §401(k)(10) successor-plan rule is a separate restriction on the buyer establishing a new 401(k) within 12 months.

5Buyer Co acquires Seller Co in an asset purchase and continues employing 90% of Seller's workforce. Seller terminates its 401(k) plan one day before closing and distributes all account balances. Why does the §401(k)(10) successor-plan rule potentially invalidate the distributions?

A.If Buyer establishes or maintains an 'alternative defined contribution plan' covering the former Seller employees within the 12-month window starting on plan termination, the §401(k)(10) distributions are not valid distributable events

B.Because Seller's termination occurred within 12 months of the asset purchase, all distributions are automatically taxable

C.Because §410(b)(6)(C) requires the Buyer to cover Seller employees for at least one year before any 401(k) terminations

D.Because the §401(k)(10) rule prohibits any plan termination during the year of an M&A transaction

Explanation: Under Treas. Reg. §1.401(k)-1(d)(4), a 401(k) plan termination is a distributable event ONLY if the employer does not maintain an alternative defined contribution plan (other than an ESOP, SEP, SIMPLE, 403(b), or 457) at any time during the period beginning on plan termination and ending 12 months after final distribution. If Buyer covers the former employees in its own 401(k), Seller's distributions fail this test.

6Megacorp sponsors a frozen overfunded defined benefit plan with $50M in assets and $30M in liabilities. To recover the $20M surplus without incurring the full §4980 50% excise tax (in addition to income tax), Megacorp can establish what arrangement?

A.A Qualified Replacement Plan (QRP) under §4980(d) that receives at least 25% of the surplus and allocates it to participants over no more than 7 years, reducing the excise tax from 50% to 20%

B.A §401(h) medical retiree account funded entirely from the surplus, eliminating all excise tax

C.A §415(m) excess benefit plan funded from the surplus, eliminating excise tax

D.A §409A nonqualified deferred compensation plan that absorbs the surplus tax-free

Explanation: IRC §4980(d) reduces the §4980 excise tax on DB reversions from 50% to 20% if the employer (1) transfers at least 25% of the surplus to a qualified replacement plan, (2) allocates the transferred amount to participants over no more than 7 years (or immediately), and (3) covers at least 95% of active participants from the terminated plan.

7To meet the §4980(d) QRP allocation requirement, surplus assets transferred to the QRP must be allocated to participant accounts under which schedule?

A.Either immediately on transfer or ratably over a period not exceeding 7 years, with any unallocated amount held in a suspense account that does not revert to the employer

B.Over 10 years using a straight-line method

C.Over the participant's remaining working lifetime, but not less than 5 years

D.In a single lump sum no later than the close of the plan year following the transfer

Explanation: Under §4980(d)(2)(B), the transferred surplus must be allocated to participant accounts no later than 7 years from the transfer date. Unallocated amounts must remain in a suspense account; they cannot revert to the employer, or the excise-tax relief is lost.

8A cross-tested new-comparability profit sharing plan groups owners into one allocation rate group and rank-and-file NHCEs into another. Under Treas. Reg. §1.401(a)(4)-8, to test on a benefits basis, the plan must satisfy the minimum gateway. Which requirement is correct?

A.Each NHCE must receive an allocation rate of at least one-third of the highest HCE allocation rate, OR an allocation of at least 5% of §415 compensation

B.Each NHCE must receive an allocation rate of at least 50% of the average HCE allocation rate, OR an allocation of at least 3% of compensation

C.Each NHCE must receive at least the top-heavy minimum of 3% of compensation

D.Each NHCE must receive a 7.5% nonelective contribution to qualify as a QACA-style gateway

Explanation: Treas. Reg. §1.401(a)(4)-8(b)(1)(vi) sets the broadly-available minimum gateway for cross-tested DC plans: each NHCE must have an allocation rate of at least 1/3 of the highest HCE rate OR at least 5% of §415 compensation. Without the gateway, the plan cannot test benefits.

9In a cross-tested plan, an HCE receives a 20% profit sharing allocation. What is the lowest NHCE allocation rate that still satisfies the broadly-available minimum gateway?

A.5% of §415 compensation (because 1/3 of 20% = 6.67%, but the 5% safe harbor cap applies)

B.6.67% of §415 compensation (must match 1/3 of the highest HCE rate regardless of the 5% cap)

C.3% of compensation as the top-heavy minimum

D.7.5% of §401(a)(17) compensation

Explanation: The gateway is satisfied if each NHCE receives the LESSER of 1/3 of the highest HCE rate or 5% of §415 compensation. With a 20% HCE rate, 1/3 would be 6.67%, but the 5% cap applies, so 5% satisfies the gateway.

10Combined DB/DC plans that aggregate for §401(a)(4) testing must satisfy a higher minimum gateway. Under Treas. Reg. §1.401(a)(4)-9(b)(2)(v), what is that floor?

A.Each NHCE must receive an aggregate normal allocation rate of at least 7.5% of §415 compensation (or the plans must be primarily DB in character)

B.Each NHCE must receive at least 5% of compensation in the DC plan and accrue at least 1% in the DB plan

C.Each NHCE must receive at least 3% top-heavy minimums in both plans

D.Each NHCE must receive an equivalent accrual rate of at least 0.5% of pay

Explanation: Treas. Reg. §1.401(a)(4)-9(b)(2)(v)(D) requires a 7.5% minimum aggregate allocation rate for NHCEs in a DB/DC combo tested on benefits (unless the combination is 'primarily DB' or meets the 'broadly available' separate-plan tests).

About the CPC Exam

The Certified Pension Consultant (CPC) is the pinnacle ASPPA retirement-plan-consulting credential, sitting at the top of the ASPPA pyramid above QKA, QKC, and QPA. CPC candidates demonstrate mastery of complex plan design (cash balance combos, §401(h) medical accounts, ESOPs, NQDC), plan terminations and corporate transactions (Rev. Rul. 89-87, §401(k)(10), §414(l), PBGC standard/distress termination, §4980 QRP), EPCRS and VFCP corrections (including SECURE 2.0 §305 SCP expansion), prohibited transactions and PTE strategy (PTE 84-14 QPAM, PTE 2020-02), ERISA fiduciary litigation risk (Hughes, Tibble, Dudenhoeffer, LaRue), and SECURE Act/SECURE 2.0 consulting (mandatory auto-enrollment, Roth catch-up effective 2026, LTPT 2-year rule, PEPs/MEPs). The exam has historically used essay/case format; candidates should plan rigorous case-analysis practice in addition to substantive knowledge review.

Questions

100 scored questions

Time Limit

Per ASPPA candidate handbook

Passing Score

70%

Exam Fee

$455 (standalone) / $895 (bundle) (American Retirement Association (ASPPA))

CPC Exam Content Outline

15%

Complex Plan Design

Cash balance + 401(k)/PS combo plans, §401(h) medical accounts within DB, §409A NQDC distribution events, §415(m) excess benefit arrangements, §409(p) S-ESOP nonallocation years, §404(a)(7) combined deduction limit with PBGC-insured DB exception, §430 at-risk funding, §436 AFTAP benefit restrictions (80% lump-sum / 60% no lump-sum), QACA §401(k)(13) match formula

12%

Cross-Tested & New Comparability

Treas. Reg. §1.401(a)(4)-8 broadly-available minimum gateway (lesser of 1/3 highest HCE rate OR 5% of §415 compensation), DB/DC combo 7.5% aggregate gateway under §1.401(a)(4)-9, EBAR computation with standard interest rate projection (5%-8.5%) and standard mortality, rate-group §410(b) testing on benefits basis

12%

Plan Terminations, Mergers & Spinoffs

Rev. Rul. 89-87 'as soon as administratively feasible' (12 months), §401(k)(10) successor plan rule with alternative DC plan trap, §410(b)(6)(C) M&A coverage relief (up to ~2 plan years), §414(l) spinoff minimum benefit, PBGC NOIT 60-90 days under §4041.23, distress termination §4041(c) four criteria, ERISA §4044 six priority categories (PC1 voluntary contributions highest), soft vs. hard freeze and §411(a) vesting service, Rev. Rul. 2007-43 20% partial termination presumption

10%

Qualified Replacement Plan

§4980 employer reversion excise tax (50% base rate / 20% reduced rate), QRP requirements: at least 25% surplus transfer + 95% active participant coverage + allocation over ≤7 years (suspense account prohibition on reversion), §401(a) qualified plan only (SEP/SIMPLE/403(b)/457(b) excluded), alternative 20% pro-rata benefit increase path

10%

EPCRS & VFCP Corrections

Rev. Proc. 2021-30 framework, SECURE 2.0 §305 SCP expansion to eligible inadvertent failures (indefinite correction window), missed-deferral safe harbors (0% QNEC for auto-enrollment within 9.5 months, SECURE 2.0 §350 extension), plan document/nonamender failures requiring VCP, anonymous VCP 21-day disclosure rule, overpayment §301 no-recoupment option, DOL VFCP for late deposits with PTE 2002-51 excise tax relief

10%

Prohibited Transactions

ERISA §406(a) per se PTs (sale/exchange, loan, services), §406(b) self-dealing, ERISA §3(14) party-in-interest, §408 statutory exemptions (§408(b)(1) participant loans only, §408(b)(2) service providers), PTE 84-14 QPAM exemption with April 2024 ineligibility amendments, PTE 2020-02 fiduciary acknowledgment + Impartial Conduct Standards + retrospective review, §4975 25% excise tax + 100% on uncured PTs

10%

Fiduciary Litigation Risk

Hughes v. Northwestern 2022 prudence-process duty, Tibble v. Edison continuing duty to monitor (statute of limitations renews per breach), Fifth Third v. Dudenhoeffer eliminated Moench presumption (pleading-standard alternative-action requirement), LaRue v. DeWolff individual-account §502(a)(2) claims, missing-participants DOL FAB 2014-01 + 2021 Best Practices + SECURE 2.0 §303 PBGC Lost & Found, cybersecurity DOL April 2021 guidance, ERISA §502(c)(1) ~$190/day document-request penalty, §404(c) menu-selection NOT shielded, §3(38) discretionary investment manager liability shift, §3(16) plan administrator

10%

SECURE Act & SECURE 2.0 Consulting

SECURE 1.0 §401(a)(9)(H) 10-year rule + IRS July 2024 final regs (RMDs required years 1-9 if death on/after RBD), EDB categories (spouse, minor child, disabled, chronically ill, ≤10 years younger), SECURE 2.0 §101 mandatory auto-enrollment for new plans 2025, §103 Saver's Match 2027, §107 RMD age 73 (75 in 2033), §110 student loan match + Notice 2024-63, §125 LTPT 2-year/500-hour rule 2025, §127 PLESA NHCE-only $2,500 Roth sidecar, §202 QLAC $200K limit, §301 overpayment relief, §304 $7K involuntary cash-out, §305 SCP expansion, §312 hardship self-certification, §314 domestic abuse distribution ($10K/50%), §326 terminal illness 84 months, §348 de minimis incentives + Notice 2024-2, §603 Roth catch-up for $145K+ earners effective 2026

Consulting Strategy

PEP conversion fiduciary trade-offs (loss of §3(16)/design control vs. PPP outsourcing), cash balance + 401(k)/PS combo design for medical/professional practices ($400K+ owner deductions), brother-sister controlled group analysis (80% common + 50% identical ownership), ASPPA Code Precept 7 conflict disclosure (unimpaired ability + disclosure + express consent), Rev. Proc. 2017-41 pre-approved plan document opinion-letter reliance, termination funding strategy (standard vs. distress eligibility)

MEPs & PEPs

ERISA §3(43)/(44) PEP architecture, IRC §413(e) one-bad-apple relief (noncompliant employer spunoff, MEP qualification preserved), PPP §3(16) plan administrator and §3(21) named fiduciary role, single Form 5500 with PEP attachments listing participating employers, SECURE 2.0 §128 403(b) MEP eligibility

How to Pass the CPC Exam

What You Need to Know

Passing score: 70%
Exam length: 100 questions
Time limit: Per ASPPA candidate handbook
Exam fee: $455 (standalone) / $895 (bundle)

Keys to Passing

Complete 500+ practice questions
Score 80%+ consistently before scheduling
Focus on highest-weighted sections
Use our AI tutor for tough concepts

CPC Study Tips from Top Performers

1Memorize the 2026 IRS limits cold: §402(g) $24,500, §415(c) $72,000, §415(b) $290,000, §401(a)(17) $360,000, HCE $160,000 — these underpin nearly every consulting question

2Master the §4980 QRP framework: 50% base excise tax / 20% reduced rate with 25% transfer + 7-year allocation + 95% participant coverage; SEP/SIMPLE/403(b)/457(b) cannot be QRPs

3Lock in the cross-testing gateway: LESSER of 1/3 highest HCE allocation rate OR 5% of §415 comp for DC-only; 7.5% for DB/DC combos

4Drill SECURE 2.0 section numbers: §101 mandatory auto-enrollment, §103 Saver's Match, §107 RMD 73→75, §110 student loan match, §125 LTPT 2-year, §127 PLESA, §202 QLAC $200K, §301 overpayment, §304 $7K cash-out, §305 SCP expansion, §312 hardship self-cert, §314 domestic abuse, §326 terminal illness, §348 de minimis, §603 Roth catch-up (effective 2026)

5Know the fiduciary litigation framework: Hughes (process duty), Tibble (continuing duty), Dudenhoeffer (Moench eliminated + pleading standard), LaRue (individual-account §502(a)(2))

6Understand the PEP architecture cold: ERISA §3(43)/(44), §413(e) one-bad-apple, PPP as §3(16) administrator, single Form 5500

Frequently Asked Questions

Is this the same CPC as the medical-coding CPC?

No. This is the ASPPA Certified Pension Consultant (CPC) — a retirement-plan-consulting credential from the American Retirement Association. The MEDICAL CPC (Certified Professional Coder) is an AAPC medical-billing credential and is a completely different exam. On this site, the medical CPC lives at the exam ID `cpc`; the ASPPA pension CPC lives here at `cpc-pension`. If you came looking for medical coding, use the medical CPC page; if you handle 401(k) and DB plan consulting, this is the right page.

What is the ASPPA CPC exam format?

CPC is a closed-book proctored online exam administered by ASPPA. Historically the exam has used essay and case-format scenarios that test consulting application of IRC, ERISA, and DOL guidance to fact patterns. The practice bank on this page uses 4-option multiple-choice items so you can drill the underlying rules and recall efficiently; before exam day, supplement with the ASPPA case-format study materials. A passing score of 70% is required.

What are the prerequisites for the CPC credential?

CPC sits at the top of the ASPPA pyramid. Candidates must already hold the QKA (Qualified 401(k) Administrator), QKC (Qualified 401(k) Consultant), AND QPA (Qualified Pension Administrator) credentials before sitting for the CPC exam. If you do not yet hold all three, complete those credentials first; the prep workload is significant.

How much does the CPC exam cost in 2026?

The standalone CPC exam fee is $455. ASPPA also offers an education + exam bundle for $895 that includes study materials and one exam attempt. Fees are not refundable. Always confirm current pricing on the ASPPA website before registering, as the American Retirement Association adjusts fees periodically.

What topics are covered on the CPC exam?

The CPC syllabus emphasizes consulting-depth content: complex plan design (cash balance combos, §401(h) medical, ESOPs, NQDC, §430/§436 funding), cross-tested new comparability (gateway + EBAR), plan terminations/mergers/spinoffs (Rev. Rul. 89-87, §401(k)(10), §414(l), PBGC), Qualified Replacement Plans (§4980), EPCRS and VFCP corrections (including SECURE 2.0 §305 SCP expansion), prohibited transactions and PTEs (PTE 84-14 QPAM, PTE 2020-02), fiduciary litigation risk (Hughes, Tibble, Dudenhoeffer, LaRue), SECURE Act/SECURE 2.0 consulting (Roth catch-up, LTPT, PEPs), and consulting strategy.

How long should I study for CPC?

Most CPC candidates plan 120 to 200 hours of study over 16 to 24 weeks. The case-format historical aspect requires not just substantive knowledge but applied analysis under time pressure; budget significant time for working through ASPPA's case-format practice scenarios in addition to multiple-choice drilling. Candidates without recent terminations or M&A experience should plan extra time on Phase 2 (terminations and transactions) and Phase 3 (corrections).

What career path follows the CPC credential?

CPC is the senior credential in the ASPPA retirement-plan-consulting track. CPC holders typically advance into senior plan-consulting, plan-actuary partnership, or compliance-leadership roles at TPA firms, consulting actuarial practices, recordkeepers, and law firm employee-benefits practices. Many CPCs also pursue the ASEA (American Society of Enrolled Actuaries) enrolled actuary credential or the JD/LLM in Employee Benefits for adjacent specialty work.