VCP Filing for missed PPA restatement

I have just inherited a new client, and, in looking at their documents, there was never a PPA restatement filed before April 30, 2016; the last document that I was provided was the EGTRRA restatement.

The client searched their records and they agree that the PPA restatement was never prepared, and have authorized the preparation of the PPA document and the VCP filing.

In 35 years in this business, I've never had to do a VCP filing, thankfully. My only question on this is: What should be the effective date of the PPA restatement? Is it something before 4/30/2016 (like 1/1/16), or should it be current, say 1/1/2022?

Thanks for any replies.

Last year a client was referred that needed both an EGTRRA restatement and a PPA restatement.  We made the EGTRRA restatement effective 1/1/09 and the PPA restatement effective 1/1/15, and both documents were signed with a current date in 2021.  Filed both with VCP and received a compliance statement with no problem.

On 3/19/2022 at 9:04 AM, bzorc said:

My only question on this is: What should be the effective date of the PPA restatement?

It should be the date that it would have been effective if adopted timely.

Thank you!