Procedure and Practices document

[glhotdog]

Current understanding is that for plan corrections there must be a Procedure and Practices document in place.  What resource are practitioners using as an example/sample document? and where is the document available?

[David D]

We paid for one last year from an ERISA attorney that provided us a notice we could use and the required HPI participant notice.  It's important to note that i believe the Practices and Procedures had to have been in place at the time the deferral was made.   https://www.law.cornell.edu/cfr/text/26/1.414(v)-2

[ERISA_Guy]

I don't think there is a writing requirement, the policies just need to be "real".  In other words, the plan has to have and follow policies designed to be compliant, but these policies don't have to be written in detail.