Retroactive Amendments under SCP

[davef]

We have discovered that an employer allowed participants to enter the plan too early for the last two years. Based on the EPCRS procedures, it looks like we can retroactively amend the plan's entry date provisions to cure the problem. A determination letter would also need to be requested on the retroactive amendment. Since this plan has not yet been restated for GUST, is it possible to fold the retroactive amendment into the GUST restatement, file for a DL and still meet the EPCRS requirements? Or is a separate DL required for the SCP retroactive amendment?