415 Amendment Deadline

[Guest ebailey]

I have a governmental 401(a) plan. It is my understanding that the remedial amendment period for 415 required amendments is the later of 7 months after end of plan year (in which remedial amendment period begins) or the last day of the next legislative session beginning after the amendment's effective date in which the plan amendment can be considered. Our remedial amendment period begins 1/1/09 as that is effective date of the amendment for our govt plan and we have a fiscal year plan year. Therefore, we think the due date for our 415 amendments is 7 months after June 30, 2009. Any confirmation or thoughts would be appreciated.