Vol Submitter plan finally gets a DL for 2009 restatement;

[katieinny]

I'd like to know if I'm making moutains out of molehills. A volume submitter plan was restated in 2009 and submitted at the same time we were all scrambling to get our restatements done in early 2010. There was a problem with the submission because the GUST document wasn't signed on time. The employer paid a penalty and the Determination Letter was finally issued for the 2009 document. For a reason that I don't entirely understand, the employer asked their provider for a new document. I think they may have been looking for an SPD, but somehow they ended up with a 2011 restated plan. The next submission is years away, and they will probably need to restate again at that time. Of course, I'm going to go through the 2011 document just to make sure that changes weren't made, but assuming everything is status quo, my thinking is to toss the 2011 document, get a new SPD for the 2009 document, and get back on track. Or should I just let them keep the 2011 document and stop worrying about it?

[QDROphile]

Are you asking whether or not it is legal to quietly dispose of a plan document that has been adopted as if it had never existed?

[Bird]

I think I'd keep the 2011 document and not worry too much about the motivations for the restatement (although if I'm providing administrative services I'd want to know if there were any changes and would review the doc).

[katieinny]

My agenda for this afternoon includes going through the document page by page to make sure that my suspicions are correct and no changes were made. The employer has NOT signed the document yet, so no, QDROphile, I'm not asking if it's legal to dispose of a signed document. If there are no changes, I'd rather they chuck it instead of sign it. I was asked to review the document to make sure it's "okay" before signing. I just don't want to have to explain to an agent the next time they restate that the 2011 document had no real purpose other than that the employer was confused and requested it.