Standardized to Individualized Plan

[Guest tintree73]

We have a standardized plan that (as of 12.31.2003) will no longer cover all entities in the controlled group - so it turns into an individualized plan at 12:01am on 1.1.2004 (amended for GUST/EGTRRA on 12.30.2002). I am assuming that we have to submit this to the IRS for a determination letter by 1.31.2004 under Revenue Procedure 2003-72 - but am I wrong in that assumption? Is there anything else I should be worred about (e.g., are there amendments that should be made before we send it to the IRS for a determination letter-if we have to do that)?

[Alf]

You can have limited reliance on prototype sponsor's letter if you just go to an nonstandardized plan. Everything else can be the same except the affilitate adoption. If you go individualized plan on 1/04, you don't have to file for a determination letter application until 3/15/05 for a calendar year plan and I expect the determination letter application process to be completely different then if you believe the proposals that the IRS is tossing around.