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PPA Restatement for Individually Designed Plan


bzorc

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Here is a question that I have regarding a plan document.

I took over a couple of plans as the TPA from a partner who retired back in 2016 from our firm. When the partner retired, they provided me the documents for the plans. They are all EGTRRA documents, with dates in 2009. The partner utilized the Relius volume submitter document for the restatement. They were filed as individually designed plans, and have a determination letter from the IRS, under the company name. I also have executed 415 and PPA amendments. One of the companies is in the process of being sold, and the purchasing company is looking for a copy of the PPA restatement for the plan. I have searched our company archives and can find no mention of a PPA restatement. 

I have reached out to Relius to see if there is a PPA restatement completed before the 4/30/2016 deadline. My question is was a PPA restatement necessary, as the plan was submitted as individually designed? I only work with Prototype plans, and have never utilized a volume submitter plan that was submitted to the IRS as an individually designed plan. Sorry for this really dumb question, but I truly have no idea.

Thanks for any replies.

 

 

 

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Just because a volume submitter was submitted for an IRS determination letter does not make it "individually designed".  VS documents with modified language are required to be submitted for D-letters, if you want one because they cannot rely on specimen opinion letter, but these are NOT IDPs and are on the 6-year cycle for restatements -  unless the modifications were extensive enough to no longer qualify as VS (I have never seen).

It is possible that the plans were submitted on a 5300 and treated as IDPs and then otherwise required to follow the 5-year restatement and submission cycle which no longer exists. In either case, there would be at least one if not two applicable cycles post 2009.

Go to the IRS website or Google 6-year (and/or 5-year) restatement cycles. Google is a wonderful thing.

All that said - you are never really REQUIRED to submit for D-letters, but you ARE required to maintain an updated plan document whether through amendments or restatements.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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