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DB Restatements

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Since I see DB plans so infrequently, I want see if I've got this straight...

DB plans using pre-approved docs need to be restated by the deadline next year.

DB plans using IDP documents, that already have a prior D-letter from the IRS, are not required to restate, (and generally can't apply for a D-letter) but do need to keep up their amendments required by the IRS annual list within the appropriate timeframes.

I realize that D-letters are now available in certain situations where they weren't previously, but I'm just confirming what MUST be restated. Thanks.

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