A DL for volume submitter even pre-1999?

[Guest DottleC]

Can a fairly new plan on a volume submitter document, assuming the plan was effective 1-1-98, request and receive a determination letter for pre-1999 law, and NOT pay the rate for customized plan document review? In other words, can a determination letter be issued for pre-Gatt sufficiency that would be based on parameters as defined in an adoption agreement? Our motivation: We could request via written letter that the determination be made as such for pre-Gatt, and feel that it is important that the plan have a determination letter, as it is a sizable 401(k) plan. It is difficult to justify the expense of submitting as customized document.