Failure to Adopt Proposed Restatement

[Guest mbg76]

We have a client who submitted a proposed restatement of its plan for a GUST determination letter in 2002. They got the letter, which was conditioned on adopting the plan within 90 days of the date of the letter. The client never adopted the plan. I know we have a plan document failure, but my question is: will filing under VCP bring that old letter back to life (i.e., does VCP mean the restatement was adopted within 90 days and thus the letter is good?) or is that letter completely dead and we need to refile everything that we submitted for the determination letter application from 2002?