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Under the PPA, a plan that has been operating as a single employer plan can file an election of multiemployer plan status with the PBGC if it meets certain criteria and sends a notice to participants, beneficiaries and employers. Plans would presumably have to adopt amendments relating to withdrawal liability, 415 limitations, top-heavy rules, etc. Does anyone know whether any regulatory guidance is expected regarding such amendments? Should we assume that the PPA's remedial amendment period applies to such amendments?

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