Randy Watson Posted July 26, 2010 Report Share Posted July 26, 2010 When does this have to be made for a plan with a Sept 1 plan year commencement date? By September 1, 2011? It seems to me that you don't actually have grandfathered status until the regs apply (in this case until September 1, 2011), so the disclosure should be made by then. Link to comment Share on other sites More sharing options...
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