Amendment for catch-up contributions

[Guest key123]

I have a client who amended their 401(k) on 1/4/10 to allow for catch-up contributions effective 1/1/2010. On 4/8/2010 they restated the plan for EGTRRA and did NOT include the catch-up provision (I’m not positive, but I think it was simply an omission when the document was prepared). On 9/21/2010 they signed an amendment to the EGTRRA document allowing the catch-ups, but made the amendment effective 1/1/2011. Should that amendment to the EGTRRA document be effective 1/1/2010 instead? The client is using a PPD non-standardized prototype.