Missing Signed PPA Restatements Documents - How to handle?

If an employer can't find signed versions of its PPA restatement documents and the recordkeeper does not maintain signed copies, are there any suggestions of what to do? Surely the documents were signed within the 2014-2016 required time period but they can't be found. The employer has the unsigned versions. Could we just sign and date on the day they were likely signed in 2015 and put those in the file?

If it truly can't be located, file under VCP as a non-amender. However, when faced with a substantial fee (IRS fee and TPA fee to file) you may be astonished at how the employer suddenly locates it. Many times the "I can't locate it" is code for "I can't be bothered to really look." Not saying that is the case here, but it often is.

As to your proposed solution, my advice is don't even think about suggesting this to a client.

Did the employer search corporate minutes, etc., to see if there is at least a resolution adopting the restated plan?

I appreciate your very good ideas. They will search the corporate minutes and old files. Possibly the "can't be bothered to really look" is the case. I'm surprised some recordkeepers don't maintain signed documents. It seems some do and nicely organize those within a client portal and with others maintain nothing.

In the previous TPA I worked for we would tell the client "It WOULD HAVE BEEN signed on such and such a date..."  for missing documents, amendments, resolutions, etc. etc.  They always came up with it.

As Belgarath states, do not even suggest the back-dating of documents - illegal and unethical.

How a RK or TPA cannot maintain a copy of the most recent signed plan document and subsequent amendments boggles my mind. How do you know you are administering the plan in accordance with the ACTUAL plan rather than your assumptions based on an unsigned draft? And that you are actually administering an updated qualified plan if you don't know for certain that it has indeed been adopted?

Back in paper days, I can see not maintaining past versions once updated (and leaving that sole responsibility to the sponsor), but in the digital age there is NO reason that both the plan sponsor and TPA (and RK if separate) each has a signed copy (even electronically signed) stored electronically. 

And thinking "of course it was signed back in XXXXXX" is faulty reasoning because many a(n emailed) document gets buried in the mailbox, deleted, forgotten, back-burnered - take your pick - and is then never signed within the required time frame.

Does anyone have any idea of the dollar amounts when it comes to IRS fines should an employer have unsigned or missing plan documents?  Would a $1M plan see IRS fines of maybe $500 or are we talking $10,000 or more?