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PPA Restatement


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A plan has a calendar plan year. The employer is moved from an individually designed plan (timely signed an 8905) and is using a pre-approved document. The PPA restated document is effective 1/1/2016.

When the employer got their PPA restatement they notified the document provider that they made a change in operation mid-2015 plan year but failed to request an amendment to the plan document.

Did the employer need to sign an amendment by 12/31/15 for the change or can the change be incorporated into the PPA document and signed by 4/30/16 (i.e., under PPA remedial amendment period). If it can be incorporated into the PPA document would is be under varying effective dates or would the PPA restatement date need to be the effective date of the change in operation (e.g., 10/1/15).

Thank you.

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