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We took over administration of a plan in 2002. I recently found out that the plan has an insurance policy. The policy was taken out in 1991. There was no mention of the insurance policy when we took over the plan. History of the plan prior to 2002 is sketchy. The company would like to correct and file under the DFVC program. I'm just not sure how to help them without knowing at what point the insurance policy was not included in the assets. Any suggestions on how to help them or where to start?

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