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Page 2 of Form 8717 states that if a plan was "first effective" on or after December 9, 1989, then it will be exempt from the user fee. Thus, brand new plans put into place on or after that date are exempt. Accordingly, if I've got an employer who set up a PSP and a MPPP on July 1, 1970, there would be no exemption from the user fee, correct? I know it's only 125/each, but I want to be sure... Thanks.

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