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Restatement effective date


Guest Pat Metallic

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Guest Pat Metallic
Posted

A plan with a 3/31/02 plan year end allowed an in-service withdrawal for an NHCE in March when the plan does NOT allow such withdrawals. As a remedy, can the GUST restatement be drafted to allow in-service withdrawals and an effective date that is before the withdrawal occurred (ie January 1)?

Posted

Most GUST restatement dates I have seen are as of the first day of the plan year beginning in 2001. I have also seen dates as early as the first day of the plan year beginning in 1997.

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

Posted

Pat, the answer to your question is no. An in-service withdrawal is not part of the items that can be operated outside the provisions of the document during the remedial amendment period.

"What's in the big salad?"

"Big lettuce, big carrots, tomatoes like volleyballs."

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