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Plan never formally adopted a plan document


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We were asked to assist a client who had a 403(b) plan since 2004 but never formally adopted a plan document or filed a Form 5500. 

If the client adopts  the plan document before the June 30 deadline, are we in compliance, or do we need to file a VCP for the plan document issue? Is the June 30 deadline only for defects to an existing plan document or can we use it for a plan that never had a plan document?

For the late 5500, the client will filed under DFVCP.

Thank you.

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