PPA Restatement for FT William Document

[jkharvey]

If any of you are familiar with the FT William document, I have a quick question, please.  I have a takeover plan that used the FT William document.  They are not providing me with an actual PPA restatement Adoption Agreement, but only a snap on amendment for the adoption agreement.  Did FT William provide an actual PPA restated adoption agreement and my client is just not finding it or did they truly only do snap on amendments to the EGTRRA Adoption Agreement?

 

Thanks

[Madison71]

Restated doc - it’s required

[Madison71]

Of Course - the sponsor may have just failed to restate, but Ft. William has a PPA doc.

[RatherBeGolfing]

FTW has several PPA restated documents.

When was the "snap on" executed?  

[jkharvey]

This snap-on was executed by the Volume Submitter sponsor on behalf of the Plan Sponsor.  it was effective 1/1/15 and executed on 11/15/2015.  The Snap-on  included language to amend the following sections:  Eligibility, Contributions (SH and Elective Deferrals), Contributions (matching PS and other Contributions),  Vesting, In-Service Withdrawals, 

[Bird]

Mmmm, I think some of the earliest PPA restatements needed a fix and that's what it sounds like.  There should definitely be a full restated AA.

[RatherBeGolfing]

8 minutes ago, Bird said:

Mmmm, I think some of the earliest PPA restatements needed a fix and that's what it sounds like.  There should definitely be a full restated AA.

Could be, but it would be a snap on to the PPA restated AA, effective 1/1/16.

[JackS]

FtW found numerous problems with their pre-approved PPA doc after the approval letter was issued.  They went back to the IRS and amended their PPA restatement.  If the clients doc was done before a certain date, there is a separate amendment related to these changes that applies.  After a certain date, the changes are incorporated into the AA.  There is a PPA restatement (AA BPD, etc) either way.    

[RatherBeGolfing]

The "fix" to the PPA document could be done two ways, you would redo the document completely, or add a snap on. 

Again, this would be an amendment to the PPA document, not EGTRRA. 

[NJ Mike]

The revised/corrected documents were put on the FT Williams system on February 23, 2015.  Any plan done on or after that date on their system was fine but if completed/signed before that date needed to either be amended or redone completely.  Individually designed plan had to be redone as I recall.