Impact of GUST Closing

[Guest Grumpy455]

What does the closing of the GUST Program mean? I have some clients who have not submitted their plans for GUST determination letter--although their plans have been amended for GUST. Should I file a GUST determination letter application for them or just wait until the EGTRRA Program opens next year? Thanks.

[g8r]

It shuts down the GUST program for opinion (M&P plans) and advisory letters (volume submitter plans). It does not shut down the GUST determination letter program.

As to whether you should submit or not, that's a loaded question. However, we don't have the EGTRRA determination letter procedure yet so there's no telling when you will be able to submit and get an EGTRRA determination letter. Presumably it will open on Feb. 1, 2006. But, if you submit out of the cycle that applies to the employer, then you may find that you have to resubmit when the cycle for the plan actually occurs (could be anytime within 5 years if an individually designed plan or probably 2008 or 2009 if using a prototype or volume submitter plan).