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Discretionary plan amendment for defined contribution plan is adopted after the end of the plan year during which is became operational. Assume it's operational during 2015 (calendar) plan year and adopted July 1, 2016. Amendment says it's effective 1/1/15. What is the effect? Is the amendment entirely void? or Is the amendment deemed effective 1/1/16 (first day of the plan year in which it was adopted), limiting the operational failure to only 2015? Or - is there another possibility?
