Cycle 3 deadline - Trust Agreement

[Tom]

As we know the deadline for signing Cycle 3 Adoption Agreements has passed.  What if a plan sponsor has not signed the now separate Trust Agreement timely - by July 31?  The Trustees are the same before and after Cycle 3.

[Lou S.]

Then don't the existing trust provisions apply?

[BG5150]

But are there no penalties for late "adoption"?

[Bri]

If the new document superseded the old one, and the prior trust provisions were in that document, did the trust provisions evaporate into the ether between July 31 at 11:59 and when the new trust document was signed?

[Tom]

We restated the Principal plan onto our document for Cycle 3 and it was executed timely.  Principal continues to hold the plan under its Trust agreement but that will change.  This one just made me a bit nervous since it is the only plan of ours whereby the plan document was signed but no trust agreement yet.     

[Bill Presson]

If we had clients continuing to operate on a different trust agreement, we noted that on the signature page. It was an option in the software. Did you do anything like that?