no plan document ever

We are early in the research process but a 403(b) plan that was created in 1989 apparently has never had a plan document.  I would like to eventually get them through VCP.  Would this be acceptable since we have nothing to go on?

Thanks

Did this plan ever have a nonelective, matching, or mandatory contribution?  Or was it always voluntary salary-reduction-only?

It has employer contributions for all years.  

Consider whether your client might use an anonymous submission to discern whether the IRS would accept the undisclosed applicant's proposal for resolving the defects.

2 hours ago, Peter Gulia said:

Consider whether your client might use an anonymous submission to discern whether the IRS would accept the undisclosed applicant's proposal for resolving the defects.

And, make sure you are dealing with a really competent ERISA attorney or consulting firm!  

18 hours ago, Santo Gold said:

We are early in the research process but a 403(b) plan that was created in 1989 apparently has never had a plan document.  I would like to eventually get them through VCP.  Would this be acceptable since we have nothing to go on?

Thanks

Santo Gold, based on your description, I had a similar case a number of years ago. We got it through VCP.

17 hours ago, Luke Bailey said:

Santo Gold, based on your description, I had a similar case a number of years ago. We got it through VCP.

Just curious if you were able to use a current document, submit that with any attachments and all of the caveats and explanations about nothing previously having been available.  Was that enough to get it through?