Late amender - Prototype document

[J. Bringhurst]

Client has prototype document that it failed to timely amend (complete and execute) for GUST and EGTRRA. Under Rev. Proc. 2003-44, would there have to be a contemporaneous determination letter filing even if this plan is a prototype document? Section 6.04 appears to provide that correction by plan amendment by adoption of a prototype would not require the determination letter filing, but I wanted to make sure.

[WDIK]

I came to the same conclusion, but I've been shown frequently on these boards to be off base.