We have a potential new client- the current document is on a "Non-Standardized Capital Accumulation Plan" Can this plan be restated as a 401(k)?

According to the client it is operating the same as a 401(k), 5500 being filed plan number 033 plus and all testing.

The 'Capital Accumulation Plan' terminology sounds like a defined contribution plan. If so, then you ought to be able to restate it as a 401k, whether the Capital Accumulation Plan did or did not in fact have a 401k feature. Only a review of the current plan document will let you know for sure what type of plan you're dealing with.

Tread lightly, Cap Accumulation Retirement Plan is aslo common name for cash balace DB plan. Get current plan doc and see what kind it is. Peak at the 5500 from prior year and check the codes on the form for fast answer to DB or DC status.