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Interim Amendments

Guest lightfingers

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Guest lightfingers

1. Under Section 1107(a)(2) and (b)(1) of PPA, there is an extended amendment period for governmental plans to adopt PPA-required amendments, which is the last day of the first plan year beginning on or after Jan. 1, 2011, and these amendments will be given retroactive effect. For an individually designed governmental DB plan qualified under 401(a) can you wait until the end of the applicable remedial amendment cycle, which is January 31, 2009, to adopt all other interim amendments required for that cycle, with retroactive effect to the date when the interim amendment was required?

2. Is there model language anywhere for the interim amendments required, or a good summary of what amendments are required, to be adopted for the current remedial amendment cycle for governmental plans which will expire Jan 31, 2009?

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