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It is my understanding that the late adoption of the Cycle 3 restatement results in the plan losing its ability to rely on the preapproved document's IRS letter and the plan becomes individually designed beginning 8/1/2022.  Further, this can be self-corrected under EPCRS so long as all of the requirements for self-correction are satisfied and the individually designed plan is compliant as an IDP.  The employer may then rely on the preapproved document's IRS letter.  My question relates to timing.  It appears you must first correct any plan document failures then adopt a new Cycle 3 document.  

Assume the client presents us with a Cycle 3 document effective 1/1/2022 and signed 8/31/2022.  We review the prior document and find it is in compliance as an individually designed plan.  Besides documenting in a Board resolution the employer's intention to self-correct what additional steps, if any, must be taken?  

I apprecate your input.  Thanks!

 

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