IDP to Prototype

[Scuba 401]

was a form 8905 required to extend deadline when converting from IDP to prototype. the plan had a cycle C (1/31/09) deadline.

[Kevin C]

To qualify for the 6 year amendment cycle, they had to either 1) adopt a pre-approved (or interim pre-approved) document by 1/31/2009 or 2) sign Form 8905 by 1/31/2009. Section 17 of Rev. Proc 2007-44 has the rules for being eligible for the 6 year restatement cycle. Although, in your case if this is a DC plan, Section 17.04(2) would apply and it says they should have adopted a newly pre-approved document by 1/31/2009.