Plan adopted in 1995, but no document updates since then

[Santo Gold]

Company adopts a standardized prototype plan in 1995 (calendar year plan). I don't have the opinion letter but I would assume it is a TRA 86 document. Nothing seems to have been done (document-wise) since then, although the admin, 5500s, distributions, seem to have been handled timely and properly.

The link below answers many questions in this situation:

http://benefitslink.com/boards/index.php?showtopic=26811

I wanted to quantify for the plan sponsor what has been missed with their document. Is saying that GUST amendments, RMD amendment, and involuntary distribution amendment (although still not really late) are needed, catch everything? Secondly, if going through VCP to correct, the user fee is $750 (10 employees). Is there usually other government fees or negotiated settlements that take place in this situation?

Thanks for comments

[Alf]

Add:

final DOL claims procedures;

EGTRRA;

JCWAA; and

Rev. Rul. 2002-27.

The only other fee I can think of is the user fee for the IRS determination letter fee if you decide that has to be included with the VCP. Although it is a standardized prototype, you may want to (have to?) include a determination letter application.