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A new client was placed in a plan claiming to be a fully-insured (412(i)) cash balance plan with a companion fully-insured profit-sharing plan. This was originated back in the mid-2000's, driven by an agent who may have regulatory issues, which we are investigating. I am challenged by several issues, and appreciate your thoughts in general, and if you have personal experience, maybe some stories or facts to share. First, it is clear that this must be an individually drafted plan. Is it possible to get copies from the IRS of any past plan submissions for qualification? None of the vendors (agent, or the three insurance companies used) has produced a plan document, although we are still pressing the issue. Second, given the disparity in contributions by policy, we need to test non-discrimination. Would a cash balance plan projection be based on the credited interest rates in the individual policies? (So far, we do not see any variable annuity policies in the history, so I expect some stability on this issue.) Third, I would expect that the fully-insured status was used to avoid an enrolled actuary certification, although I would expect that the insurer had actuarial review on the proper premiums for each policy. How does this meet the requirements for avoiding EA review, given that this is not a level premium safe-harbor design for a flat benefit or unit benefit plan with a minimum 25 year accrual rate (as far as I can determine so far)? Any suggestions or comments would be appreciated.