Amendments to frozen plan

[Guest Penelope]

I am restating a long-frozen IDP in anticipation of termination and a 5310 filing. The plan has one participant. No contributions have been made for more than five years. The plan has a GUST letter, a good-faith EGTRRA amendment and a PPA amendment. The employer is a Cycle E filer.

The plan document provides for permitted disparity, graded vesting and a service requirement for participation. I'd like to get rid of these provisions in the restatement, as they are irrelevant given the plan's frozen status. I was planning on giving the restatement a general effective date of 1/1/2010, with specific earlier effective dates as required. Can I drop the unneeded provisions from this restatement? If so, can I do so effective as of an earlier date than 1/1/2010?

[Guest Grumpy456]

I have that very same question--albeit with slightly different facts. In my case benefits participation (new entrants) was frozen in 2008 (a soft freeze). As of 1/1/2009 benefits were frozen (a hard freeze) and vesting was accelerated to 100%. Whatever benefit a participant had accrued under the plan document that existed on 1/1/2009 is the benefit a participant has now (and will have). That plan document was the client's GUST document and it received a favorable determination letter. This plan is a Cycle E plan too and I need to restate it by 1/31/2011. Like you, I would like to make the restatement as simple as possible--and leaving out the historical benefit/accrual formulas, among other stuff, will help a lot. Anyone have any thoughts? Thanks!

[Guest Grumpy456]

In discussing my question with a colleague, I'm told that Accudraft does exactly what Penelope and I are asking about--once a freeze date is entered, any subsequent restatement is stripped of benefit formula/accrual formula, etc. Anyone out there use Accudraft (I don't) that has experience with this?