Defined Benefit Late Restatement - SCP eligible?

We have a client that failed to sign their DB restatement prior to 7/31/2020 - despite numerous requests from us to do so. Am I reading the IRS website correctly that, since this failure occurred after April 19, 2019 (EPCRS Rev. Proc. 2019-19 update) and will be corrected within the SCP 2-year timing, that correction for this failure is eligible under SCP? An article I've read seem to interpret this expansion to exclude restatements since, due to the late restatement, the plan sponsor may no longer rely on the prior restatement period opinion letter, but that does not appear to be how the IRS is describing correction here. 

Assuming the plan is eligible for SCP, should the document be dated as of the current date with a notation that the adoption is late but the plan is taking advantage of the correction method under SCP??  

https://www.irs.gov/retirement-plans/401k-plan-fix-it-guide-you-havent-updated-your-plan-document-within-the-past-few-years-to-reflect-recent-law-changes

From article (my highlighting added):

Correction programs available:

Self-Correction Program:

Some, plan document failures may be corrected on or after April 19, 2019 under SCP if certain conditions are met. The conditions are:

• Plan document failures must be corrected within the two-year correction period specified in Rev. Proc. 2019-19, section 9. The failure begins in the plan year that includes the end of the applicable remedial amendment period.
• Plan must have a favorable letter as defined in Rev. Proc. 2019-19, section 5.01.
• SCP is not available to correct a failure to timely adopt an initial IRC 401(a) plan document.
• Corrective amendments to resolve demographic failures that were not timely adopted are not eligible for SCP and must be resolved under VCP or Audit CAP.
• The late adoption of discretionary amendments is not considered a plan document failure.
• Refer to Rev. Proc. 2019-19, sections 4.01, 4.03, 4.04 and 4.05 for program eligibility requirements.

Example 1:
The Carrot Stick Company has sponsored a 401(k) plan since 1997. They use a pre-approved plan document.  On May 3, 2019 the plan sponsor realized that they failed to timely amend their plan for EGTRAA by the April 30, 2010 deadline and for PPA by the April 30, 2016 deadline respectively. The EGTRRA document was adopted on June 30, 2015 and the PPA document was adopted on December 5, 2018. Can these failures be considered resolved under SCP per Rev. Proc. 2019-19?

The answer is no. The failures can’t be resolved under SCP. The correction of the failures occurred before April 19, 2019, the effective date of the revenue procedure. Prior to 4/19/19 the correction of these failures needed to be accomplished via VCP or Audit CAP. Even if the failures had been uncorrected they would still be ineligible for SCP under Rev. Proc. 2019-19 because correction would be occurring after the end of the 2 year period for correcting significant failures under SCP. That period would have ended on 12/31/12 for the EGTRRA failure and 12/31/18 for the PPA failure.

I am currently looking at this same issue and was thinking the same thing as you thought. Any further insights?