VCP and Non Amender

[jeff77]

We are preparing a VCP submission along with a EGTRRA document restatement for a plan that didn't restate for EGTRRA. What effective date do we use for the restatement? A date in the restatement period or something like 1/1/15?

[John Feldt ERPA CPC QPA]

Depends on the document. Some documents require a January 1, 2002 retroactive effective date for the EGTRRA restatement with special effective dates for each change that occurred after that. Others simply require a current effective date and the document internally has hard-wired each of the required retroactive effective dates for the various provisions.

[Peter Gulia]

John Feldt, that is the clearest thing I have ever read about preapproved documents. Thank you!