DB Document updates

I'm not a DB person, but a question came up as to required amendments for the past "several" years. These are a couple of plans that are evidently frozen (at what year I don't know) and that haven't been updated, apparently, for 4 or 5(ish) years. They are not cash balance/hybrid plans, not union, not governmental, (but one is apparently a non-profit) and apparently HAVE received IRS approval letters at some point in the past. They want to terminate the plans. I do not know if they are pre-approved plans or not - I'm speculating "not" but I don't know.

Looking at the IRS cumulative list, it doesn't appear that there is too much required in the way of DB amendments going back to 2016. Do you agree that this would generally be the case, or am I missing something obvious? Of course, if they are terminating, they would have to also be updated for CARES/SECURE as applicable, but that's a separate question.

Just looking for general thoughts. Thanks.

If they have d-letters, looking at the letters might indicate whether they were on prior 5-year cycle for IDP which has since gone away or are pre-approved with modifications on a 6-year cycle. I agree not much has been going on in DB amendment world and these may be OK, but it would be prudent to do a detailed review prior to going down termination road.

Thanks, appreciate the thoughts. We don't have anything to do with these plans anyway - just a question that came up out of the wild blue yonder...