Is a restated document required when submitting a pre-approved plan for review within its remedial amendment cycle, or can all the amendments be attached to the existing document?
A restated document is generally required for a VS and M&P plan, except when an adopting employer to an M&P plan makes changes to the underlying plan document. Any changes adopted by the employer must be made in the form of an amendment and not incorporated into the underlying M&P plan document. Changes to a pre-approved VS plan may either be incorporated into the VS document or made as separate “tack-on” amendments to the plan. If the changes are incorporated into the document, the application must also include a list describing the changes. 3. Has the Service determined whether employers filing off-cycle applications for determination letters under section 14 of Rev. Proc. 2007-44 will be processed in any order and will priority be given to some of these applications? Generally, off-cycle applications will not be reviewed until all on-cycle plans have been reviewed and processed. However, under Rev. Proc. 2007-44 some applications will be given the same priority as on-cycle applicati
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