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401(a)(9) Final Regs Plan Document Failure

Guest J Brody

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Guest J Brody

City 401(a) Defined Contribution plan was not amended by 12-31-2003 for 401(a)(9) final regulations. 2 participants terminated service in 2003 and elected lump sum distribution. I believe the recommended course of action should be adoption of model amendment and enter EPCRS VCP for 2003 calendar year. Any thoughts?

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