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Posted

Earlier this month, I prepared an SB for 2012 using the same plan provisions that were used for the past few years. Two of those provisions are:1) NRA of 62 and 5 years of service and 2) eligibility based upon 1000 hours. Subsequently, I realized that the GUST and EGTRRA adoption agreements actually had NRA as 61 and 5 and that the EGTRRA adoption agreement (but not the GUST adoption agreement had eligibility based upon elapsed time. The person in our office who prepared the EGTRRA adoption agreements erroneously made this "elapsed time" change for many plans and I'm confident that the plan sponsor did not intend to amend the eligibility to elapsed time. Moreover, I am fairly certain that NRA in both adoption agreements is a mistake. Can these two corrections be made now and enable me to file the SB with the provisions always used? Any help would be appreciated!

Posted

Your assumed retirement age for valuation purposes does not have to match the NRA in the plan document. It is just your assumed retirement age.

If it was truly a mistake in the document, then just fix the document and move on. You might consider a VCP filing as a cleaner fix.

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

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