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Does a Terminating Pre-approved Plan Need To Be Restated for PPA?
FIS Relius
[Guidance Overview] June 17, 2014
"Plans do not need to be restated for PPA, even when being submitted to the IRS for a determination letter upon termination using Form 5310 ... However, if a plan is not being submitted to the IRS for a determination letter on plan termination, then we recommend that the plan be restated, whenever possible, onto a PPA pre-approved document. This way the employer can be assured the plan language satisfies the changes made by PPA (and the other changes in the law that are included in the PPA document)."
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