Group Submission to VCP

[cpc0506]

Hello. We just took over the document responsibility for over 120 clients of an investment firm.

The investment firm was the document provider using an Relius Standardized Prototype In review of the EGTRRA restatements done by the investment house, there are very few Final 415, HEART, WRERA amendments and no PPA amendments in the files. The Investment Firm indicated that they did not adopt any amendments on behalf of their clients, but each were to sign the amendment. Needless to say that did not always happen.

So, we are in the process os submitting all of the plans of the clients of the investment firm under VCP using a Group Submission. Has anyone done this lately? If so, can you provide an estimate of the time the process took and what you might have charged for the submission work?

As part of the submission you are required to notify all plan sponsors who adopted the plans, that the plans are being submitted to VCP. Does anyone have a sample letter that they have used to inform the plan sponsors of the Group Submission.

Thanks for any guidance you can provide.

[ETA Consulting LLC]

If it were a Relius "Prototype", then you'd typically not rely on the statements of the investment firm. Chances are that Relius did, indeed, draft default amendments to the Basic Plan Document supporting the prototype adoption agreement; and they were merely not distributed. This is one of the main advantages of using a prototype as opposed to an individually drafted plan; the automatic amendments written by the vendor to keep the plan's language current.

Now, whether or not the actual default language matches the plan's operation would be a different story. I would probably do a little more digging before pushing the 'group submission' button.

Good Luck!

[cpc0506]

First, we currently use Relius for our documents and yes, we as the document provider, did adopt all interim amendments on behalf of all our clients. And we have a copy of the amendment signed by our owner.

However, the investment firm informed us, after numerous questions, that they never signed any interim amendments at the plan sponosr level on behalf of their clients and when they drafted the adoption agreements and provided the packet to their clients, the 415, HEART and WRERA admendments all drafted to require an Employer signature. And they never even provided the PPA amendment.