We have recently taken over an individually designed cash balance plan effective 11/1/2007. The prior TPA argues that because it was an individually designed plan, it was not required to be restated for EGTRRA. The plan was, however, amended for 436 and HEART. In addition, I find it concerning that the original plan document does not come with a favorable determination letter. Is it correct that this individually designed plan does not require a FDL or any restatements? Would appreciate any guidance you can provide.
