NON STANDARDIZED PROTOTYPE PSP did not amend for GUST/EGTRRA nor did it ever apply for determination

[Lori H]

upon our review of a 2 participant psp with an effective date of 1/1/95, they never updated for gust/egtrra, which we agreed needed to be submitted under VCP. upon digging deeper, the original non-standardized prototype doc was never submitted for determination. should this be disclosed under the VCP? we are updating to a gust approved Standardized prototype doc.

[Guest B2Randolph]

In order to get a GUST/EGTRRRA letter as part of the VCP submission, the determination letter 5300 or 5307 indicates that you are to include all amendments since the last determination letter, so they want a copy of the plan document all the way back anyway.

However, they didn't have to have a determ letter - it is not required, although most want to get it anyway since you do need it for VCP and other reasons.

[Lori H]

In order to get a GUST/EGTRRRA letter as part of the VCP submission, the determination letter 5300 or 5307 indicates that you are to include all amendments since the last determination letter, so they want a copy of the plan document all the way back anyway.

However, they didn't have to have a determ letter - it is not required, although most want to get it anyway since you do need it for VCP and other reasons.

However, they didn't have to have a determ letter - it is not required, although most want to get it anyway since you do need it for VCP and other reasons

can you rely on a form only determination letter issued on a non-standardized prototype without subbmitting for an opinion on the effect of other federal or local statutes?

all non-standardized plans i've come across have been submitted for determination