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Sponsors of Non-Calendar Year 403(b) Plans Seem to Have December 31, 2009 Plan Document Adoption Deadline
McDermott Will & Emery 
[Guidance Overview] Dec. 15, 2008
Excerpt: Note that this relief applies only to the 2009 calendar year, which implies that plan sponsors operating their plans on a basis other than a calendar year basis must adopt a plan no later than December 31, 2009, regardless of whether the end of the plan year occurs outside of 2009.
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