New plans and addon amendments

[SoCalActuary]

A plan sponsor wants to start a qualified DB plan for 2009.

If we provide a prototype document containing the required eligibility and benefit language by year end, must we also provide an add-on amendment for all post-GUST items at the same time? Can those add-ons be attached to the basic document without requiring an added signature?

Can we include in the adoption resolution that all required amendments are incorporated automatically without separate signature?

For background purposes, we are using Corbel prototype standardized documents sponsored by our own firm.

[Kevin C]

Your prototype document most likely allows amendments at the document sponsor level. If you adopt at the sponsor level and your interim amendments will be identical for each plan, you won't need the employer's signature on the amendments, unless the employer elects an optional provision in the amendment. Our current document provider took that approach. There is a note at the end of each interim amendment saying the employer doesn't need to sign unless an optional provision is selected.

Corbel might have adopted some or all of the interim amendments as document sponsor. If they did, there should be a similar note at the end of the interim amendments.