GUST SPD due date?

[Guest Hilarion]

Our prototype plan document was restated for GUST in 2001 and the Service issued opinion letters on 11/30/01. Is the due date for GUST SPDs on all the restated plans in July, 2002 (210 days after the end of the plan year in which the amendment was adopted)?

Or can we defer until January 1, 2003, the date by which summary plan descriptions have to be rewritten to comply with the DOL regs that became final on March 8, 2002?

If neither, does ERISA have a "hardship" provision that would allow us, the pitiful, beleagered, overwhelmed trustee of 6,000+ plans, to defer SPD distribution?