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  1. Have a new client that is a Governmental Hospital in the state of Texas. Presently has a 403(b) plan and moving to a 457 Govt Plan. Under the Hospital umbrella they have a subsidiary that is a 501(c)3 organization (with a separate EIN#) and would be considered part of a control group. Currently those employees are all participating in the same 403(b) plan, however, the 501(c)3 entity is not listed on the present adoption agreement. I have reviewed the Advisory Opinion 2003-16A and Section 501(r) Compliance. Could they be considered an agency or instrumentality of the Hospital and be included in the 457 Govt Plan under same document?
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