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Cash Balance Restatement - Cycle A

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Plan was cash balance Defined Benefit with a GUST determination letter. This plan was restated on July 2006 to a non cash balance plan using a GUST volume submitter.

The employer EIN ends in 6, so my question is: Since cycle A for individually designed plans is from 2/1/06 to 1/31/07, should this plan have been amended for EGTRRA before being amended onto the volume submitter document?


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