Updating documents since 1997

[Jim Chad]

Does anyone have recent experience with this? In filing VCP will I need all of the amendments for each law change or can I just restate for EGTRRA and PPA?

[John Feldt ERPA CPC QPA]

Technically they are not late for the PPA restatement, so that would not have to be submitted, but might be useful to submit anyway as way to document the late execution of the interim amendments needed after the EGTRRA restatement.

Do they have an executed TRA 86 document? If not, I you may need a TRA 86 restatement.

Otherwise, you need a GUST restatement and an EGTRRA Restatement. If you don't do a PPA restatement with the application, then you need them to adopt each of the interim amendments that apply after EGTRRA restatement (eg. 415, HEART, WRERA, PPA) and submit those. If they adopt PPA now, that handles all of the interim amendents, other than Roth Transfers (conversions for those account not eligible for the usual in-service - if the plan does that).

All of the interim amendments between GUST and EGTRRA are all late, sure, but they all get adopted when the EGTRRA document is executed. Again, same concept with the interim amendments after the EGTRRA restatement - they get adopted with the PPA restatement.