Cycle 3 restatement missing

Have a  new take-over client with a PPA pre-approved VS document effective 1/1/21.  The plan sponsor says the prior TPA was very difficult to work with, never available, never responsive, etc., etc.  The plan sponsor also indicates that he never received a Cycle 3 restatement from the prior TPA.  I'm not surprised since I don't know why the TPA would have used a PPA document for the initial adoption back in December 2021.  Anyway, we are to provide a Cycle 3 document to correct.

The IRS guidance for late amenders is to treat the plan as individually designed and adopt an amendment for the missing provisions; then restate onto a Cycle 3 document.  Does anyone know of an amendment template that would pick up the required provisions since PPA to the present?  The document provider I use did publish an amendment for the final Hardship Distribution regulations, as well as CARES/SECURE.  What more would have to be added?

Thanks.

I suggest that you try to pose this question to the plan's original document provider.  They are the most knowledgeable about what they provided and how they addressed all of the LRMs for each year in question.  For example (and not a suggested course of action), they may have provided a termination amendment for the PPA document that would have added all of the required provisions needed should the plan have terminated before the Cycle 3 document was needed.

If the plan's original document provider is uncooperative, you may want to pose this question to you current document provider to get similar input.  Some document providers will sort this out for a plan but they may charge a consulting fee.