We are submitting a plan for determination. The plan has been on a standardized prototype since its effective date - January of 1988.

Because the plan has never been submitted for determination before, the IRS is asking for every Opinion Letter and every Adoption Agreement executed between 1988 and 2003. No problem, with one exception: the Opinion Letter that was applicable when the plan became effective (1988) is not to be found.

The client never received a copy. The retirement association which sponsored the plan changed trustees/document sponsors in 1989 so we have no idea where to turn for this Opinion Letter.

I'm not sure what to do here. Any suggestions?

www.benefitslink.com/boards/index.php?act=Attach&type=post&id=73079

The other reply with the IRS guidance is good. As well depending on the agent and where they are located they may be able to look up the M&P letter on their micro fiche files.
It depends if the agent is willing to or not.