off cycle restatement

[Guest latwz]

Hi, I have a client with a 2002 restatement and 9 amendments. They are a Cycle E filer. It has been suggested that we do a Plan composite and have the client sign the composite as a "restatement"? Will this cause any issues? Cycle E filing issues?

I assume that we can file the 2002 Plan (w/FDL), the 2008 "restatement, the 2011 restatement and all amendment from 2002. However, would the IRS consider this 2 restatements? I assume that the 2008 restatement was really an Amendment? An I wrong?

Begining with Cycle C, all submission must include a redline copy showing all changes. I wonder if this would cause additional issues since we would have to provide possibly 2 redlines (2002 to 2008 and 2008 to 2011).

Any thoughts would be appreciated!