IDP without current DL

[TPApril]

How common is it for a plan document preparer to not submit for a Determination Letter? Individually Designed Plan had a prior DL which expired and though IDP was restated timely, no DL was requested. What if the plan needed to file a VCP?

[Peter Gulia]

What matters is whether a practitioner furnished enough information and explanation so that his or her client could have made an informed choice about whether to seek a determination letter.

[TPApril]

Hard to imagine a Plan Sponsor being well informed and choosing not to apply.

Plan in question is so basic, I'm thinking they should just move on to a prototype or volume submitter to reduce the issue of continually applying.