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We are taking over a plan of an Employer has a volume submitter profit sharing plan. The prior TPA did not have the ER sign Form 8905 and the EIN ends in 6. My first reaction was panic, but maybe I overreacted. Am I correct that this Employer will still be eligible for the 6-year cycle provided he meets the requirements outlined at Section 17 of Rev Proc 2007-44? Just because the ER did not sign Form 8905 by 1/31/2007 (Cycle A deadline) does not mean that the plan was not timely amended for EGTRRA?

Thank you

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