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Posted

Is it a plan failure requiring correction if the wrong Trustee was named in the plan document?

Adoption Agreement lists the Board of Directors of the plan sponsor as the Trustee, but they actually hired a corporate Trustee several years ago. There is a trust agreement in place naming the corporate trustee.  The Adoption Agreement explicitly states that a plan amendment is not necessary to change the information in Trustee section of the agreement. 

 

Posted

Maybe I'm confused but is it possible the new trust agreement was simply a plan amendment? If that's the case you probably have a late SMM if the participants haven't been notified of the change.

Posted

You're confused, I think I was overanalyzing the issue. But after further research, I agree with you on the late SMM. Thanks!

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