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For the new small plan audit rules, when does the bonding requirement on nonqualifying plan assets have to be in place? Is it enough for the bond to be effective as of the last day of the plan year? Would it have to be effective on every day of the plan year?

For plan years starting May 1, 2001: if a plan has 15% nonqualifying plan assets as of April 30, 2001, when does the plan need to meet the additional bonding requirement in order to avoid the audit requirement?

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