SheilaD Posted December 8, 2008 Share Posted December 8, 2008 Everything I read says the deadline for a calendar year DC plan to adopt 401(a)(9) was December 31, 2003. But -- I have an old DC amendment checklist that indicates January 31, 2004 was the deadline. It was sooooo long ago and I cannot recall why I have that alternative date. I cannot find it on CCH or in the ERISA Outline Book. Perhaps my younger pension self was led astray by some side comment. Does anyone remember this alternative deadline? Link to comment Share on other sites More sharing options...
Guest Sieve Posted December 11, 2008 Share Posted December 11, 2008 1/31/2004 was the drop-dead date for GUST restatements (with payment of an additional $350 user fee, if I remember correctly, and a mandatory application for a favorable determination letter). That extended GUST restatement date included the good-faith EGTRRA amendment (which also included, as part of that, the final 401(a)(9) regulations). At least that's my recollection. See Rev. Proc. 2003–72. Section 3 specifically deals with 401(a)(9) amendments. Link to comment Share on other sites More sharing options...
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