Under the old rules, Regional Prototype plans had to keep a master list and submit it to the IRS annually.

Now that there are no more regional plans, is there a procedure of notification if a client refuses to restate their document? We are sending the client a certified letter and dropping him from our master list. But somehow, that doesn't seem to be enough.

There is no procedure. You are doing the right thing by sending a certified letter. And, I believe that under Rev. Proc. 2000-20, you need to keep the employer on your list for 3 more years. After that, you drop them from the list.

The real concern I'd have is liability with the employer -- not what the IRS will do if you don't follow the Rev. Proc. Sure, the IRS could revoke your prototype letters. But I think that's unlikely to happen. Again, the bigger concern is the employer that misses the deadline and blames your firm. That's why I always suggest that you send a certified letter.