I hope this is a simple question. I am foggy on it for some reason.

Brand new plan. Signed and effective February 1, 2010. We know PPA amendments are due on the last day of the first plan year beginning on or after January 1, 2009. Plan year here is calendar year.

Even though it won't be a full plan year, is the PPA deadline the last day of the 2010 plan year or December 31, 2010?

Then, when are the 2010 amendments due?

Add to that, I'm filing for a DL. If I amend, won't I have to restate, and won't all this blow the client's head off?

Propose: file for DL. Then, stand alone amendment for PPA before 12/31/2010. Done.