Individually Designed Plan- PPA Update

[coleboy]

My boss gave me an adoption agreement to review for a possible new client. This was an individually designed document. I don't believe that a determination letter was ever acquired. The document was done in 2009 with an amendment to add safe harbor in 2010.

There was stuff in this adoption agreement that made me want to run away. I was not comfortable with some of the language. I asked if there was a new adoption agreement that was restated to the PPA,etc.

The response was he added in the PPA language when he amended the plan for safe harbor in 2010. He stated that since it was only a few sentences, the TPA would have a hard time finding the PPA provisions within the document unless the TPA actually drafts documents and knew where to look.Hence,

That was 6 years ago. Shouldn't the document have been restated again? Should I have reason to worry other than it makes me want to run away?

[UtahCPA-APA]

Seems to me the Individually designed plan PPA restatement period, depending on EIN, was between 2011 and 01/31/2016. No need to run. Plans like these are why they pay us the big bucks, lol.