Rev Rul 2002-27

[Guest RS Vatalaro]

This isn't exactly GUST related but I don't know where else to post.

This question regards the required compensation amendments for plan sponsors w/ certain cafeteria plan language. A vast majority of my plans as TPA are using the prototype of a certain investment house.

I asked the legal counsel of this investment house if they would be sending out Rev Rul 2002-27 amendments to all registered users and the response was that Corbel (the original drafter) would likely send the required updates to the investment house at some point, and then the investment house would send the update to the registered users some time after that.

I was given the impression that it would be a loooong time before this happens. I have never encountered this issue before. Would you just use the model amendment available for your clients? Or would you wait for the investment house via Corbel?

I just don't want to miss any deadlines because I relied on someone else to do the amendment (nor do I want to do duplicate work). Additionally I didn't get a lot of confidence from the investment house that I could rely on the amendment to be sent to me in a timely fashion - yet I thought one of the benefits of using a prototype was not having to worry about required updates.

Thanks for any opinions.