Relius DB Restatements - Cycle D

[Blinky the 3-eyed Fish]

This is a specific Relius Cycle D question.

It's my understanding that Cycle D submissions will review PPA provisions (i.e. they are on the applicable Cumulative List). If anyone that uses Relius didn't notice, their original DB PPA amendment was a load of crap and they corrected it with a new release in December sometime.

The problem is that the Cycle D documents have that load of crap PPA language in them. The 436 language is the biggest culprit. They also come with a PPA amendment that seems to incorporate some of the provisions not already in the document. In other words it's a cut-down version of the full PPA amendment because many of the provisions are in the document body.

Has anyone noticed this? If so, what are you doing, assuming you don't want to have the client sign a document that has bad 436 language in it? My initial thought is having the client sign an entirely new PPA amendment, even though they signed a good PPA amendment previously. That new amendment would override the bad language in the document.

[John Feldt ERPA CPC QPA]

Since you're submitting for a D letter you should be able to submit good language later when the IRS reviews the plan language, that's what we intend to do. I'm really not sure what else can be done at this time if the plan year end was December 31st.