Guest KMP Posted January 10, 2007 Posted January 10, 2007 A new client of ours let us know that they have been doing administration on their plan based on an SPD. No one can locate a copy of the actual document. We want to go through VCP to submit a GUST document. Will we also have to provide a pre-GUST document or all copies of plans from the effective date? Has anyone ever done this and had success? Thank you!
david rigby Posted January 10, 2007 Posted January 10, 2007 Is it possible that the prior TPA resigned because this client is a black hole? I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
namealreadyinuse Posted January 11, 2007 Posted January 11, 2007 You are on the right track I guess. We have gone back to ERISA before, but always had an initial plan document. I think that is your problem here. I would definitely file anonymous.
MPLSLAW Posted June 6, 2007 Posted June 6, 2007 Just received a compliance letter for retro adoption of a missing in action SAR-SEP plan document. We had no employer documents to submit other than the SEP-IRAs.
Guest BXO Posted June 13, 2007 Posted June 13, 2007 On a related note... The VCP filing for a plan without a GUST (or TRA '86, for that matter) document? Assuming 20 participants, is it the $750 noted Section 12.02 of EPCRS? I ask because that seems like a reasonable amount for 20 years worth of missed document updates. Thanks.
401_4_ever Posted June 14, 2007 Posted June 14, 2007 I don't have the Rev Proc in front of me, but I believe it's $750 for a non-amenders program regardless of the number of participants.
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