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403b restatement effective date

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We are looking for some clarification. The way we are reading the guidelines, the effective date of the restatement period is the later of January 1, 2010 or the plan effective date. 

Example: 403b plan that was effective 10/1/1991 and restated 10/1/2012. Are we now restating effective 1/1/2010 or 10/1/2012? 

Our innital reaction was to use 1/1/2010, but we are second guessing that because of the later 10/1/2012 restatement. 

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