A plan sponsor just signed the GUST restatement for an individually-designed plan, missing the 2/28/02 deadline and the 9/3/02 relief.

What are the corrective steps and costs?


Also, was the 2/28 deadline a submission deadline or execution of the document?

Was any action taken prior to September 2002? E.g., any chance the board of directors had a copy of the plan document before it and authorized the amendment prior to that date? The corporate resolution can be used for a "signature" provided that they had the document before them.

Unfortunately not- the prior service provider did not give them the document until February 03