retroactive amendment of insignificant error

[Guest stakri]

I have a plan sponsor that allowed an employee to participate one year too early (1/1/2004). The employee left in 2/05 and requested a direct rollover to new employer's plan. EPCRS sanctioned correction method is to do a retroactive amendment. I am not clear whethera short-form application for determination (Form 6406) has to be filed for the retroactive amendment of an insignificant operational error, any thoughts? Also, the Plan is a nonstandardized prototype, am I missing any issues with doing a retroactive amendment in the first place?

Any thoughts are greatly appreciated!