SB Pension - Katie
Apr 12 2011, 01:57 PM
We're getting ready to go through the VCP for a late amender plan. Do we need to have original signature pages to submit, or can we use signature pages that have been emailed to us?
Thanks!
DMcGovern
Apr 12 2011, 02:53 PM
Rev. Proc 2008-50, Section 11.07 - you have to include a signed submission (signed by the Plan Sponsor or Sponsor's authorized representative). The VCP checklist does indicate that this must be an original signature.
SB Pension - Katie
Apr 12 2011, 03:01 PM
QUOTE (DMcGovern @ Apr 12 2011, 12:53 PM)

Rev. Proc 2008-50, Section 11.07 - you have to include a signed submission (signed by the Plan Sponsor or Sponsor's authorized representative). The VCP checklist does indicate that this must be an original signature.
Thank you!
Sieve
Apr 12 2011, 04:14 PM
If you have a power of attorney, then the submission (i.e., the cover letter) need not be signed by the plan sponsor, because 11.07 allows an authorized representative to sign the submission itself. And, you do not need original signatures on the amendments. But, you do need an original signature of the sponsor on the penalty of perjury statement (11.09).
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