GUST Restatement - Multiple Effective Dates

[Christine Roberts]

In restating an ERISA 403(B) plan for GUST compliance, is it advisable to state different effective dates for each component of the GUST changes - e.g., make the cash-out increase to $5,000 effective for plan years beginning after August 5, 1997, but make the elimination of the look back rule for purposes of determining $5,000 cash out effective March 22, 1999.

Won't this make for a very confusing document? Is stating each effective date even necessary given that there is no IRS review process? And, even if each effective date were stated, shouldn't the effective date be keyed to when the adopting employer actually changed its procedures to be in line with the GUST provisions?