Delays in GUST determination letters on combined money purchase stock

[KJohnson]

I have an ESOP that was sumbitted for a GUST determination letter as a combined money purchase/stock bonus. ( Post-EGTRRA I "stripped out" the money purchase portion after giving a 204(h) notice). Then the Plan was subsequently terminated. I filed a 5310 on the termination.

I called with regard to the 5310 and the apparent problem is that I still haven't received my GUST letter

I was informed by the GUST screener that they had received guidance that two user fees and two applications were required for combined money purchase/stock bonus plans and that all plans that had not provided multiple user fees were shipped back to Cincinatti. That guidance was subsequently withdrawn, the plans shipped back to screeners but that the screeners still did not know how to go forward.

Has anyone else heard anything similar? I had one combined plan go through without any problem.

[QDROphile]

We have seen quite a bit of confusion and variability among reviewers. The IRS never had a uniform articulated or enforced policy in the first place and everything got out of control. The IRS has this funny antipathy toward ESOPs combined with letting all sorts of improprer practices and lore build up, sometimes with its own misguided help. You have to have some sympathy. ESOPs are a misbegotten square policy peg in the more or less round ERISA/ qualifed plan hole. The professionals shouldn't complain, though. They get fat at this trough.