401(a)(9) Amendments

[PJ2009]

Happy Friday!

Back in 2003 I recall that the IRS gave DB an indefinite extension of time in which to adopt the 401(a)(9) good faith amendment.

1. Is this extension still in effect?

2. I take it this means that DC plans are required to adopt such amendment. Does anybody know what the deadline was? I may have a plan that did not timely amend.

3. If the plan did not timely amend, should they simply amend now (late) and then "face the music" when they file the amended and restated plan for EGTRRA?

Thanks!!