Failure of M/P Plan to adopt 401(a)(9) Amendment

[smm]

What options are available to a M/P sponsor that failed to adopt 401(a)(9) Model Amendment by 12/31/03. Amendment has since been adopted. Go in under EPCRS as a "group" submission? What if there are fewer than 20 employers that adopted the M/P plan.

[Guest dietpepsi]

Individual VCP's unless you can come up with 20 systemic failures. Did you have any MRD failures for other types of plans besides MP?