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A non-governmental 457(b) plan is terminating.  However, the plan document was never updated for PPA, HEART, and WRERA.  I understand that any plan correction cannot be through VCP, but the plan sponsor has option for the IRS to review their 457(b) plan document or consider any other document form issue by requesting a private letter ruling?

In a related issue, in distributing assets upon plan termination, what procedures can the plan sponsor implement when distributees cannot be located?

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