Recently handled a takeover PSP which was on a prototype document. Plan was initially effective Jan. 1, 1989. Amended and restated on a pre-approved volume submitter document with a few language changes. Submitted the plan to the IRS for a determination letter. IRS agent recently requested all plan documents and amendments from 1-1-1989 to present. Was able to find a favorable determination letter that Plan received back in 1991. Prior prototype sponsor also forwarded to me the 2001 prototype doc. approved by the IRS and employer adopted the doc. before the end of the 2001 plan year.
I should not have a problem with persuading the agent to start the review from the most recent FDL, i.e., 1991, however, does anybody know when the proptotype sponsors had to amend their prototype documents for the 401(a)(17) and 401(a)(31) changes? I cannot imagine that the prototype sponsor (a law firm) did not make those amendments in a timely manner, however, if so, they failed to send me those pursuant to my information request. Thanks for any help that can be provided......