Keogh rollover doc requirements

A friend established a Keogh/HR10 in 1984 for his self-employed, sole-proprietor, no-employee business. He has filed informational 5500 returns properly as required. Charles Schwab and Co., Inc. is his plan document provider and account custodian. He does not have a copy of the original plan nor intermediate restatements for the first 30 years, but has all restatements since 2015. Contributions stopped in 2002.

 He wants to convert the account to a rollover IRA. He believes (as the administrator of his Keogh) to do the conversion he must have all restatements and original plan document in his possession.

 Only by trying multiple support calls to Schwab, lengthy through their tiers of expertise, can he sometimes get one more plan restatement that is missing, sometimes not.

 

He is quite anxious about exposing his retirement account to disqualification, and would like to avoid penalty if possible. Is his situation a) ignorable – he does not need original and all restatements, b) do you know of a knowledgeable, direct Schwab contact for his situation, c) amenable to the IRS employee plan compliance resolution process (Rev. Proc. 2021-30 and later, voluntary correction program), or d) how does he find a third-party retirement plan administrator (TPA firm) that could provide historical Schwab Keogh plan restatements? Or other options?

In a hyper-technical sense, he is supposed to be able to have documentation either back to the last individual favorable determination letter issued to his own plan, or all the way back if he was using prototypes. In practicality, the IRS won't go back more than the current document and the last restatement, so he is ok. I commend him for his diligence but it is way, way way over the top.