All - I work in ASC Document Support and am normally just a "lurker" on this site, but want to clear up any confusion that may have been caused by a comment made earlier in this post regarding ASC's collapsible AA. I can assure ASC's clients that if they generate a collapsed version of our PPA DC VS PS/401(k), the plan absolutely has reliance on the plan's IRS Advisory letter. The only stipulation, as required by the IRS, is that the ER/Plan Sponsor must also be provided a blank copy of the full, uncollapsed version of the AA so that the ER/Plan Sponsor can see all of the other choices that cannot otherwise be seen in the collapsed AA.
It may be that there was some confusion between the PPA DC PS/401(k) and the pre-approved 403(b) plans in that the IRS would not permit a collapsed AA for pre-approved 403(b) plans. Therefore, we do not offer a collapsed option for the pre-approved 403(b) plans - not even for internal use only.
Also, with regard to Cycle 3 DC, the IRS announced late last year that if a collapsed AA will be offered under Cycle 3, a separate IRS opinion letter will be required (whereas under PPA DC, one letter covers both the full and collapsed versions). Due to the large number of our clients that prefer using the collapsed AA, ASC is offering collapsed versions of both our Standardized and Nonstandardized Cycle 3 PS/401(k) plans.
Thank you!