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JAY21
I can't remember when the Volume Submitter DB restatement cycle begins though I think it is in 2010. Anyone know ?
Deflector
I believe you are correct and it starts in 2010. However, I am not an attorney. This is what my attorney has told me.
J4FKBC
If your DB plan is an individually designed plan, and you want IRS reliance on the plan's language (meaning you want a D letter), then your restatement is (or was) required based on the last digit of the sponsor EIN, with several exceptions. Take a look at Rev. Proc. 2007-44 for those details. EINs ending in 1 or 6 generally had a deadline of 01/31/2007, 2 and 7 had until 01/31/2008, and so on. If you don't want a D letter, you do not need to restate. However, that excludes you from some of the things allowed under EPCRS (I think), and you are breaver than me to not want IRS D letter reliance.

If your DB plan uses a pre-approved document, such as a prototype, then the EGTRRA restatement window will open sometime around February 1, 2010. To compare, the DC window was to open around 01/31/2008 and the IRS actually opened it on March 31, 2008.

http://www.irs.gov/retirement/article/0,,id=146977,00.html

If your firm is a document sponsor for a DB prototype, you should be listed here:

http://www.irs.gov/pub/irs-tege/egtrra_listdb.pdf
JAY21
Thanks for the good info.
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