Failure to Adopt 403(b) Plan Document

[Randy Watson]

This is probably going to sound like a crazy question. If a 403(b) plan sponsor adopted a written plan document in 1999, but hasn't adopted any amendments since the plan was adopted in 1999, can they submit under the new EPCRS for failing "to adopt a 403(b) Plan in accordance with the final regulations", or is the availability of that correction procedure limited to those who NEVER adopted a written 403(b) plan document until after 12/31/2009? See, told you it was crazy.

[Kevin C]

Try Section 6.10(3) of Rev. Proc. 2013-12.