Single VCP filing for multiple plans?

[Lame Duck]

I have a client who sponsors three idetical plans. All of the plans have not been amended for EGTRRA and the interim amendments. The plan is to restate all three plans and then merge them into a single plan. My question is whether I can merge them prior to the VCP filing and do a single filing or if i will need to submit on behalf of each plan. There is something in the instructions that says if you have multiple plans, such as a profit sharing plan and money purchase pension plan, you will need to submit separately for each plan, but it doesn't address plans that have been merged.

Thanks for any help.

[Flyboyjohn]

Since no one else has responded I'll offer my suggestion to submit 3 VCP applications and not muddy the waters with trying to amend first.

Once you've gotten the 3 compliance letters then do your merger.

[Lame Duck]

That is what I told the client, but I was hoping to save it a little money.

[Kevin C]

I agree 3 submissions would be the way to go. There is more involved in a merger than just the plan document. Also, have they been filing separate form 5500s each year? If so, they have been telling IRS/DOL they have three plans for each of those years.