Attachment I-A for Form 4461-A, Application for Approval of Pre-approved Defined Benefit Plan (revised 8/20) 

 Note: This application is designed to be used in conjunction with Rev. Proc. 2017-41. A list of required modifications is also recommended 
 for use and may be obtained from the IRS website at www.irs.gov/ep. 
 In items 9 through 11 indicate the article or section and page number of the        N/A  Article or Section and  Change  For IRS Use 
 plan  where  the  following  provisions  are  contained.  All  questions  must  be       Page Number                     Only 
 answered. If not applicable, check “N/A” column; otherwise complete the 
 “Article or Section and Page Number” column.  Governmental and Non-electing 
 church plans may not be subject to many of the qualification requirements 
 identified on this attachment. If not applicable, 
 check “N/A” column. 
  
 9 Provisions applicable to all plans:                                                                                    
  a  Definitions: 
       Where does the plan define the following terms- 
       (1)  Year of Service?                                                                                              
                                                                                                                          
                                                                                                                          (1) 
       (2)  Break in Service?                                                                                             
                                                                                                                          
                                                                                                                          (2) 
       (3)  Hour of service under Department of Labor Regulations,                                                        
       including service with all employers aggregated under sections                                                     
       414(b), (c), (m), or (o), and service of any individual considered                                                 
       an employee for purposes of this plan under section 414(n) or 
       (o)?                                                                                                               (3) 
       (4)  Elapsed time?                                                                                                 
                                                                                                                          
                                                                                                                          (4) 
       (5)  Plan year?                                                                                                    
                                                                                                                          
                                                                                                                          (5) 
       (6)  Compensation as defined in section 414(s) as limited by section                                               
       401(a)(17)?                                                                                                        
                                                                                                                          (6) 
       (7)  Average annual compensation?                                                                                  
                                                                                                                          
                                                                                                                          (7) 
       (8)  Earned income as defined in section 401(c)(2)?                                                                
                                                                                                                          
                                                                                                                          (8) 
       (9)  Employee as described in sections 414(b), (c), (m), (n), or (o)?                                              
                                                                                                                          
                                                                                                                          (9) 
       (10) Leased employee as described in section 414(n) or (o)?                                                        
                                                                                                                          
                                                                                                                          (10) 
       (11) Highly compensated employee as defined in section 414(q)?                                                     
                                                                                                                          
                                                                                                                          (11) 
       (12) Owner-Employee?                                                                                               
                                                                                                                          
                                                                                                                          (12) 
       (13) Self-employed individual?                                                                                     
                                                                                                                          
                                                                                                                          (13) 
       (14) Normal retirement age?                                                                                        
                                                                                                                          
                                                                                                                          (14) 
       (15) Straight life annuity?                                                                                        
                                                                                                                          
                                                                                                                          (15) 

                                                           1 of 10 

 9 (continued)                                                                                  N/A  Article or  Change  For 
                                                                                                 Section          IRS 
                                                                                                 and Page         Use 
                                                                                                 Number           Only 
 b Minimum participation standards:                                                                               
 (1) Are the requirements for participation under the plan determined without regard to 
     maximum age?                                                                                                 (16) 
 (2)  Will a new employee, otherwise eligible, participate on the earlier of the first day of                     
     the first plan year after meeting the minimum age and service requirements of                                
     section 410(a)(1) or 6 months 
     after satisfying such requirements?                                                                          (17) 
 (3)  Does the initial eligibility computation period begin with the date on which the                            
     employee first performs an hour of service, and do subsequent eligibility                                    
     computation periods: (1) begin with the anniversary of such date, or (2) shift to the                        
     plan year in accordance with section 2530.202-2(b) of the Department of 
     Labor regulations?                                                                                           
                                                                                                                  (18) 
 (4)  Is the computation period for determining a break in service the                                            
     same as is used to compute a year of service for eligibility after the initial 
     computation period?                                                                                          (19) 
 (5)  If all years of service are not counted for participation purposes,                                         
     is the service not counted excludable under section 410(a)(5)(B), (C), or (D)? 
                                                                                                                  (20), 
                                                                                                                  (21) 
 (6)  Will an employee otherwise eligible, who is in an ineligible class of employees,                            
     immediately participate on becoming a member of 
     an eligible class?                                                                                           (22) 
 c Accrual of benefits:                                                                                           
 (1) Does the benefit formula provide for wear-away and fresh-start rules?                                        
                                                                                                                  (23) 
 (2) Does the plan provide for the determination of a participant’s frozen accrued                                
     benefit?                                                                                                     
                                                                                                                  (24) 
 (3) Does the plan provide for adjustments to frozen accrued benefits?                                            
                                                                                                                  
                                                                                                                  (25) 
 (4) Does the current benefit formula provide for no permitted disparity and does it use the                      
     fractional accrual rule?                                                                                     
                                                                                                                  (26) 
 (5)(a) Does the plan provide for a cash balance formula?                                                         
                                                                                                                  
                                                                                                                   (26A) 
     (b) Is this a nonstandardized plan?                                                                          
                                                                                                                  
                                                                                                                   (26A) 
     (c) Is Hypothetical Account Balance defined?                                                                 
                                                                                                                  
                                                                                                                   (26A) 
     (d) Is Principal Credit defined?                                                                             
                                                                                                                  
                                                                                                                   (26A) 
     (e) Is Interest Credit defined?                                                                              
                                                                                                                  
                                                                                                                   (26A) 
     (f) Is there a preservation of capital requirement?                                                          
                                                                                                                  
                                                                                                                   (26A) 
  (g) Does the plan allow for the Interest Crediting Rate applied to a Participant’s beginning                    
 Hypothetical Account Balance for each Interest Credit Period to be the Actual Rate of                            
 Return on the aggregate assets of the Plan for that period?                                                      
                                                                                                                   (26A) 

                                                         2 of 10 

 (g)(1) If the Actual Rate of Return is used does it include both positive and negative             
 returns?                                                                                           
                                                                                                     (26A) 
 (g)(2) If an Actual Rate of Return is used are plan assets diversified so as to minimize the       
 volatility of returns in accordance with Reg. § 1.411(b)(5)-1(d)(5)(ii)(A)?                        
                                                                                                     (26A) 
 (h) If there is a provision for offsets accrued under a defined contribution plan, does the        
 plan provide a minimum accrued benefit to participants (expressed as a lifetime annuity            
 commencing at normal retirement age) of no less than .5% of compensation for each year             
 of credited service, which is not reduced by the offset applied to other formulas under the 
 plan?                                                                                              
                                                                                                    
                                                                                                     (26A) 
 (6) Does the current benefit formula provide for permitted disparity?                              
                                                                                                    
                                                                                                     (27) 
 (7) Does the plan define covered compensation, final average compensation, and taxable             
     wage base?                                                                                     
                                                                                                     (27A) 
 (8) Does the plan provide adjustments for benefits beginning at a time other than                  
     normal retirement age?                                                                         
                                                                                                     (27B) 
 (9) If the plan provides for permitted disparity, must mandatory employee                          
     contributions be allocated to a separate account?                                              
                                                                                                     (27C) 
 (10) If fully insured, does the plan provide for permitted disparity with respect to employer-     
     provided benefits?                                                                             
                                                                                                     (27D) 
 (11) If the plan is integrated, is the employer-provided benefit limited in accordance with        
     section 401(a)(5)(D)?                                                                          
                                                                                                     (27E) 
 d Benefits Increases:                                                                              
 For a fully insured plan, or a plan that provides an insured death                                 
 benefit, is there a provision for purchasing additional contracts due to increases in 
 compensation?                                                                                       (28) 
 e (1) Does the plan define an accrual computation period?                                          
                                                                                                    
                                                                                                     (29) 
 (2) Does the plan define a year of credited service?                                               
                                                                                                    
                                                                                                     (30) 
 (3) Does the rate of accrual under each benefit formula satisfy one of the following               
     tests at all times: 
     (a) 3 percent rule-section 411(b)(1)(A)?                                                        (31) 
     (b) 133-1/3 percent rule-section 411(b)(1)(B)?  (NOTE: A cash balance plan must                
     meet this rule exclusively.)                                                                   
                                                                                                     (31) 
     (c) Fractional rule-section 411(b)(1)(C)?                                                      
                                                                                                    
                                                                                                     (31) 
     (d) For a cash balance formula, is the accrued benefit expressed as a lifetime annuity         
     in the plan’s normal form commencing at a participant’s normal retirement age                  
     calculated by projecting the participant’s hypothetical account balance to normal              
     retirement age with interest at the interest crediting rate in effect at the date of 
     determination and converting the projected account to an actuarial equivalent benefit          
     in the normal form payable at normal retirement age using the plan’s actuarial                 
     assumptions?                                                                                   
                                                                                                     (31) 
     (e) Fully insured plan rule-section 411(b)(1)(F)?                                              
                                                                                                    
                                                                                                     (32) 
 (4) Does the plan provide for pre-ERISA accruals?                                                  
                                                                                                    
                                                                                                     (33) 
                                                       3 of 10 

  (5) For purposes of determining accrued benefits, is the normal retirement benefit            
  equal to the greater of the early retirement                                                  
  benefit under the plan or the benefit beginning at normal retirement age? 
                                                                                                (34) 
  (6) Do plan participants continue to accrue benefits without reduction in the rate of         
  accruals solely on account of the attainment of any 
  specified age?                                                                                (35) 
  f Employee contributions:                                                                     
  (1)  If the plan is non-standardized, does the plan provide for nondeductible                 
  voluntary employee contributions?                                                             
                                                                                                (36) 
  (2) Does the plan provide a separate account for the portion of each employee’s accrued       
  benefit derived from nondeductible voluntary employee contributions? 
                                                                                                (37) 
  (3) Are nondeductible voluntary employee contributions (adjusted for investment               
  experience) nonforfeitable at all times? 
                                                                                                (38) 
  (4) Does the plan require that deductible voluntary employee contributions will be            
  maintained in a separate account? 
                                                                                                (39) 
  g Section 415 limitations:                                                                    
  
  Are annual benefits limited as required by section 415?                                       (40) 
  h Distribution provisions:                                                                    
  (1) Does the plan state the normal form in which benefits will be paid (life annuity, 10      
  years certain and life thereafter, etc.)? 
                                                                                                (41) 
  (2) Does the plan specify the actuarial assumptions to be used in determining actuarial       
  equivalence which comply with Regulations 
  section 1.417(e)-1?                                                                           (42) 
  (3) Are the optional forms of benefits stated in the plan?                                    
                                                                                                (43) 
  (4) If the plan disregards service attributable to a distribution in computing the            
  employer-derived accrued benefit, does the plan                                               
  contain provisions that satisfy Regulations section 1.411(a)- 7(d)(4)? 
                                                                                                (44) 
  (5) If the present value of the accrued benefit is greater than $5,000, is consent of the     
  participant and spouse (if applicable) required when benefits are immediately                 
  distributable within the meaning of 
  Regulations section 1.417(e)-1?                                                               (45) 
  (6) (a) Does a married participant automatically receive a qualified                          
   joint and survivor annuity (QJSA), and an unmarried participant the 
   normal form of life annuity?                                                                 (46) 
   NOTE:  Effective 6/26/2013, a same sex spouse must be recognized 
   for purposes of sections 401(a)(11) and 417. 
  (b) Is the participant given an opportunity to make a qualified election to waive the         
   automatic form of payment in a manner which satisfies section 417(a)(2)                      
   during the election period 
   described in section 417(a)(6)(A)?                                                           (46) 
  (c) Is a married participant who waives the QJSA given an opportunity to elect                
   to receive a qualified optional survivor annuity in accordance with section                  
   417(a)(1)(A)(ii)?                                                                            (46) 
  (7) (a) Does the plan provide that the spouse of a deceased participant will receive a        
   qualified preretirement survivor annuity (QPSA) that requires payments not                   
   less than the amount specified in section 417(c)(1) in the event of death                    
   before the annuity starting date? 
                                                                                                (46) 
  (b) Is the participant given an opportunity to make a qualified election to waive the         
   QPSA in a manner which satisfies section 417(a)(2) during the election period                
   described in 
   section 417(a)(6)(B)?                                                                        (46) 
  (8) Does the plan designate or enable the employer to elect the percentage (not less than     
  50% nor more than 100%) of the 
  survivor annuity provided under the QJSA?                                                     (46) 
                                                  4 of 10 

 (9) (a) Does the plan provide for a written explanation of the automatic form of                
     payment in a manner which satisfies 
     section 417(a)(3)(A)?                                                                        (46) 
 (b) Does the plan provide for a written explanation of the QPSA in a manner which               
     satisfies section 417(a)(3)(B)? 
                                                                                                  (46) 
 (10) Do benefits under the plan begin, unless otherwise elected in writing, no later than       
 the 60 thday after the latest of the close of the plan year in which: (i) the participant 
 attains the earlier of age 65 or the plan’s normal retirement age, (ii) the 10  th              
                                                                                                 
 anniversary of the year in which the participant began participation under the                  
 plan occurs, or (iii) the participant terminates his or her service with the 
 employer?                                                                                       
                                                                                                  (47) 
 (11) If the plan contains an early retirement provision which requires or could require         
 both a minimum age and service for eligibility, does a participant who meets the                
 service requirement but separates from service before meeting the age requirement               
 begin to receive benefits (unless otherwise elected) upon meeting the age 
 requirement?                                                                                    
                                                                                                  (48) 
 (12) Does the plan provide that the terms of any annuity contract purchased and                 
 distributed by the plan to a participant or spouse 
 shall comply with the requirements of the plan?                                                  (49) 
 (13) Are annuity contracts nontransferable when distributed?                                    
                                                                                                  (50) 
 (14) Does the plan require, in accordance with section 401(a)(9), that:                         

 (a) Distributions be made beginning not later than the required beginning date?                 
                                                                                                  (51) 
 (b) Payment of the participant’s interest be made at least as rapidly as under the              
 method used prior to death, when the 
 participant dies after distribution has started?                                                 (51) 
 (c) Payment of the participant’s interest be made within 5 years of the participant’s            
 death, unless one of the exceptions in section 401(a)(9)(B)(iii) or (iv) applies, when           
 payment of the 
 participant’s interest has not begun prior to death?                                             (51) 
 (d) Distributions, if not made in a single sum, will satisfy the minimum distribution            
 rules of section 401(a)(9) and the regulations thereunder, including the                         
 minimum distribution                                                                             
 incidental benefit requirement of Regulations section 1.401(a)(9)-6, 
 Q&A-2?                                                                                           (51) 
 NOTE: Effective 6/26/2013, any provision under section 401(a)(9) 
 applicable to a participant’s spouse includes a same sex spouse. 
 (15) Does the plan provide that any preretirement death benefits are incidental?                 
                                                                                                  (52) 
 (16) Does the plan permit distributions only at normal retirement age, plan termination,         
 termination of employment, death, disability or 
 attainment of age 62?                                                                            (53) 
 (17) (a) Does the plan provide for the direct rollover of an eligible                            
     rollover distribution to an eligible retirement plan?                                        (54) 
     NOTE: Effective 6/26/2013, a same sex spouse must be recognized for purposes 
     of the rollover rules of IRC 402(c). 
 (b) Does the plan provide for the automatic rollover of a                                        
     mandatory distribution over $1,000 to an individual retirement plan, unless the 
     participant elects otherwise?                                                                (54) 
 (c) If provided in the adoption agreement, does the plan specify the types of plans              
     that it will accept rollovers from? 
                                                                                                  (54) 
 (d) If the plan accepts rollovers made on or after January 1, 2013 and converts those            
     rollovers to additional annuity benefits for the participant, is the amount of the           
     additional annuity attributable to the rollover determined in accordance with                
     sections 411(c)(2)(B) and (C) and 411(c)(3) of the Code and 
     Rev. Rul. 2012-4?                                                                            
                                                                                                  (54) 

                                                        5 of 10 

 (18) If the plan provides for suspension of benefits upon reemployment with the                     
 employer or continued employment beyond normal retirement age, does this                            
 provision comply with Department of Labor regulations? 
                                                                                                      (55) 
 (19) If the plan offers a benefit payment option whereby a participant can elect to                 
 bifurcate the distribution of their accrued benefit so that part of the benefit is                  
 distributed in the form of an annuity and the remainder in a more accelerated                       
 form of payment, does the method used to compute each portion satisfy one of                         (56) 
 the two methods found under Regulations section 1.417(e)-1(d)(7)?    
 (20) Does the plan contain pre-termination restrictions?                                            
                                                                                                      (57) 
 (21) Does the plan limit the accrual and payment of benefits as required by section 436?            
                                                                                                      (57A) 
 i. Vesting provisions:                                                                              
 (1) Is a computation period for vesting purposes specified in the plan?                             
                                                                                                      (58) 
 (2) Is the computation period for determining a break in service the same as is used to             
 compute a year of service for vesting? 
                                                                                                      (59) 
 (3) Does the plan provide that an employee will be fully vested on reaching normal                  
 retirement age? 
                                                                                                      (60) 
 (4)(a) Are vesting options limited so that at all times they will provide a percentage of           
 nonforfeitable rights which is not less than the percentage that would be provided                  
 under one of the options 
 under section 411(a)(2)?                                                                             (61) 
 (b) If this is a cash balance plan, is the minimum vesting required not less than 3                 
     year cliff (3 year -100%)?                                                                      
                                                                                                     
                                                                                                      (61) 
 (5) If all years of service are not counted for vesting purposes, is the service not counted        
 excludable under section 411(a)(4)?                                                                 
                                                                                                      (62) 
 (6) Does the plan contain the vesting break in service one year holdout provision?                  
                                                                                                      (63) 
 (7) Does the plan contain the vesting break in service rule of parity?                             
                                                                                                     (64) 
 (8) Does the participant who has at least 3 years of service have a reasonable period of           
 time after the adoption of an amendment which directly or indirectly affects the                   
 calculation of his or her nonforfeitable percentage (including a change to or from a               
 top- heavy vesting schedule) to elect to have his or her nonforfeitable                            
 percentage computed without regard to the amendment? 
                                                                                                     (65) 
 (9) Does the plan provide protection against cutback of vested rights or rights to                 
 accrued benefits under sections 411(a)(10)(A) and 
 411(d)(6)?                                                                                          (66) 
 (10) If participants may withdraw their contributions or earnings on them, may the                 
 withdrawal be made without forfeiting vested 
 benefits based on employer contributions?                                                           (67) 
 (11) If benefits under the plan are forfeited when a participant or                                
 beneficiary cannot be located, does the plan provide for a reinstatement of 
 the benefit if a claim is made?                                                                     (68) 
 j Top-heavy:                                                                                       
 (1) If this plan does not fulfill the basic top-heavy plan requirements at all times, does         
 the plan define the following terms-                                                               
                                                                                                     (69) 
 (a) Key employee?                                                                                  
                                                                                                    
                                                                                                     (69) 

                                                   6 of 10 

     (b) Top-heavy plan?                                                                        
                                                                                                
                                                                                                (69) 
     (c) Top-heavy ratio (as defined in section 416(g))?                                        
                                                                                                
                                                                                                (69) 
     (d) Permissive aggregation group?                                                          
                                                                                                
                                                                                                (69) 
     (e) Required aggregation group?                                                            
                                                                                                
                                                                                                (69) 
     (f) Determination date?                                                                    
                                                                                                
                                                                                                (69) 
     (g) Valuation date?                                                                        
                                                                                                
                                                                                                (69) 
     (h) Present value?                                                                         
                                                                                                
                                                                                                (69) 
 (2) Does the adoption agreement provide a section for the employer to specify the              
     interest rate and mortality table used in determining the top-heavy ratio because of       
     the required aggregation of 
     multiple plans?                                                                            (69) 
 (3) Does the plan provide that for the purpose of determining the top- heavy ratio, the        
     accrual rate used will be that used to accrue benefits under all defined benefit plans     
     of the employer, or where                                                                  
     there is no such uniform rate, the lowest accrual rate permitted under section 
     411(b)(1)(C)?                                                                              (69) 
 (4) Does the plan provide an accrued benefit (determined without regard to social              
     security) which is at all times not less than 2% of the highest 5 consecutive years’ 
     average compensation for each year of service (service may be limited to service 
     while the plan is top-heavy and to a maximum of 10 years of service) for each 
     nonkey employee participant who has completed 1,000 hours of service including 
     a nonkey employee who: 

     (a) fails to make mandatory contributions to the plan?                                     
                                                                                                (70) 
     (b) is excluded from the plan because compensation is less than a stated amount?           
                                                                                                (70) 
     (c) is not employed on the last day of the accrual computation period?                     
                                                                                                (70) 
     (d) has his or her accrued benefit reduced in any way because of permitted disparity?      
                                                                                                (70) 
 (5) If the minimum accrued benefit in (4) is in a form other than a life annuity at normal     
     retirement age, is such minimum accrued benefit at least equal to the actuarial            
     equivalent of the required 
     minimum accrued benefit?                                                                   (71) 
 (6) Are forfeitures of the minimum accrued benefit prohibited in the event a                  
     participant:                                                                                
     (a) works beyond the normal retirement age? 
     (b) withdraws mandatory employee contributions?                                            
                                                                                                 
 (7) (a) Does the plan provide for vesting not less favorable than the vesting described in     
     section 416(b)? 
                                                                                                (73) 
     (b) If the any portion of the benefit is determined under a cash balance formula is        
         the vesting at least as favorable as 3 year cliff vesting?                             (73) 

                                                         7 of 10 

 k Amendment and termination:                                                                       
 (1) Is there a provision for the Provider to amend the plan and does the provision                 
     describe the circumstances under which the Provider will no longer be authorized to            
     amend the plan 
     on behalf of adopting employers?                                                                (74) 
 (2) Is there a provision for the employer to amend the plan to satisfy sections 415 and            
     416 because of the required 
     aggregation of multiple plans?                                                                  (75) 
 (3) Does the plan prohibit adopting employers from amending other than elective                    
     provisions (except to the extent necessary to satisfy section 415 or 416 because of            
     the required aggregation of multiple plans, or as permitted by section 8.03 of Rev.            
     Proc. 2017-41) unless the employer wants to cease participation in the plan? 
                                                                                                    
                                                                                                     (75) 
 (4) Is there a provision for the employer to amend the plan to add certain model,                  
     sample, or other required interim amendments that specifically provide that their              
     adoption will not cause the plan 
     to be treated as individually designed?                                                         (75) 
 (5) Are the rights of all affected employees to benefits accrued to the                            
     date of termination or partial termination, to the extent funded as of such date, 
     nonforfeitable?                                                                                 (76) 
 (6) Does the plan provide that after merger or consolidation with, or transfer of assets or        
     liabilities to any other plan, benefits on a termination basis will be no less than before     
     the merger, 
     consolidation, or transfer?                                                                     (77) 
 l Miscellaneous plan provisions:                                                                   
 (1) Does the plan prohibit the assignment or alienation of benefits except as 
     provided by section 401(a)(13) and 414(p)?                                                      (78) 
 (2) Do loans to plan participants satisfy the requirements of section 4975(d)(1) and the           
     joint and survivor annuity requirements, if 
     any?                                                                                            (79) 
 (3) Does the plan provide that corpus or income may not be diverted                                
     for purposes other than the exclusive benefit of employees or their                            
     beneficiaries?                                                                                  (80) 
 (4) Does the plan provide that if it does not attain or retain qualification, the employer         
     can no longer participate under the plan?                                                      
                                                                                                     (81) 
 (5) Does the plan provide that if the employer maintains a plan of a                               
     predecessor employer, service with the predecessor employer is counted as 
     service with the employer?                                                                      (84) 
 (6) Does the plan provide that in the event of any conflict between                                
     provisions of the plan and the terms of the associated trust, custodial account, 
     or any other documents incorporated by reference, the provisions of the plan                    (85) 
     will control? 
 (7) Does the plan provide that in the event of any conflict between the provisions of the          
     plan and any insurance contracts issued thereunder, the plan provisions shall                  
     control?                                                                                        (86) 
 (8) If the plan provides for investment in insurance contracts, does it provide for the            
     disposition of dividends and other credits?                                                    
                                                                                                     (87) 
 (9)(a) Does the plan or adoption agreement if applicable, contain the Provider’s or                
 Provider’s authorized representative’s name, address, and telephone number for the 
 purpose of answering employer’s inquiries?                                                          (88) 
     (b) Does the plan or adoption agreement if applicable, contain a cautionary statement          
     describing the limitations on employer reliance on an opinion letter and that the              
     failure to properly fill out the adoption agreement may result in disqualification of the      
     plan? 
                                                                                                     (88) 
     (c) Does the plan or adoption agreement if applicable, contain a statement which               
     provides that the Provider will inform the adopting employer of any amendments                 
     made to the plan or of the discontinuance or abandonment of the plan? 
                                                                                                     (88) 

                                                 8 of 10 

      (d)  Does the plan or adoption agreement if applicable, provide that the employer must                                    
       complete a new adoption agreement or signature page upon first adopting the plan?                                        
       Does it also provide upon any modification to a prior election, the making of a new                                        
       election, or a restatement of the plan, a new signature page or adoption agreement must                                  
       be completed by the employer?    
                                                                                                                                
                                                                                                                                 (88) 
        (e) Does the plan or adoption agreement if applicable, contain a dated employer                                         
        signature line?                                                                                                         
                                                                                                                                 (88) 

       (10) Does the plan contain provisions that satisfy section 401(a)(37) and incorporate                                    
        the requirements of section 414(u) of the Code 
        (USERRA)?                                                                                                                (89) 
       (11) Does the plan NOT contain any sub-trusts for life insurance?                                                        

       (12) If the plan may be adopted as a multiple employer plan within the meaning of section                                
        413(c), does the plan:                                                                                                  
                                                                                                                                
  (i) include, as an addendum to the adoption agreement, a participation agreement, to be signed                                
  by any employer that adopts the plan (other than the “lead” employer that signs the adoption 
  agreement), which provides that the participating employer agrees to be bound by the terms of                                 
  the plan and trust as adopted by the lead employer, including any amendments thereto and any                                  
  elections made by the lead employer, except to the extent the participation agreement allows                                  
  for, and the participating employer makes, separate elections with respect to its employees; and                              
                                                                                                                                
  (ii) provide that for purposes of participation and vesting the adopting employer and all                                     
  participating employers are considered a single employer, and an employee’s service includes                                  
  all service with the adopting employer or any participating employer?                                                         
                                                                                                                                
                                                                                                                                 (89A) 
  Complete if you are filing for a Standardized Plan                         N/A                    Article or  Change   For IRS 
                                                                                                    Section              Use Only 
                                                                                                    and page 
                                                                                                    number 
                                                                                                                
  (10) With respect to this standardized plan:                                                                          
       a. Does the plan cover all employees (including individuals required                                             
          to be considered employees according to section 414(n) or (o)                                                 
          and employees of other members of groups aggregated under                                                     
          section 414(b), (c), (m), or (o)) other than employees who may                                                
          be excluded under section 410(a)(1) or (b)(3)?                                                                 (90) 
                                                                                                                
       b.  Are the eligibility requirements not more favorable for highly                                               
          compensated employees, as defined in section 414(q), than for                                                 
          other employees?                                                                                               (91) 
       c. Does the plan document, or adoption agreement if applicable                                                   
          contain, in close proximity to the employer’s signature line, the                                             
          circumstances under which the adopting employer may rely on                                                   
          the opinion letter as well as those where they may not rely on                                                
          the opinion letter (as set forth in section 7 of Rev. Proc 2017-
          41)?                                                                                                          
                                                                                                                         (92) 
       d. If this plan is a restatement of a non- pre-approved plan which                                               
          allowed for mandatory employee contributions onto a                                                           
          standardized pre-approved plan, do the mandatory employee                                                     
          contributions cease at the point of restatement?                                                              
        
                                                                                                                         (102) 

                                                         9 of 10 

 e. If the plan previously provided for mandatory employee                                                                    
    contributions, does the plan define the accrued benefit derived                                                           
    from employer contributions as the total accrued benefit, less                                                            
    the accrued benefit derived from mandatory employee                                                                       
    contributions as provided in Regulations section 1.411(c)-1?                                                              
                                                                                                                               (103) 

  Complete if you are filing for a Nonstandardized Plan                                             N/A   Article or  Change   For IRS 
                                                                                                          Section              Use Only 
                                                                                                          and page 
                                                                                                          number 
 (11) With respect to this nonstandardized plan:                                                                                 
                                                                                                                      
 a.  Does the plan require mandatory employee contributions?                                                                  
                                                                                                                               (102) 
                                                                                                                      
 b.  If the plan previously provided, or currently provides for                                                               
    mandatory employee contributions, does the plan define the                                                                
    accrued benefit derived from employer contributions as the total                                                          
    accrued benefit, less the accrued                                                                                         
    benefit derived from mandatory employee contributions as                                                                   (103) 
    provided in Regulations section 1.411(c)-1? 
                                                                                                                      
 c. Is the accrued benefit attributable to mandatory employee                                                                 
    contributions nonforfeitable at all times?                                                                                
                                                                                                                               (104) 
                                                                                                                      
 d.  Does the plan meet the minimum age and service requirements                                                              
    of section 410(a)(1)?                                                                                                     
                                                                                                                               (105) 
                                                                                                                      
 e.  Does the plan exclude categories of employees from                                                                       
    participation in addition to those who may be excluded under                                                              
    section 410(a)(1) or section 410(b)(3)?                                                                                    (105) 
                    f.      Does the plan document or adoption agreement if applicable,                                       
                            contain in close proximity to the employer’s signature line, the                                  
                            circumstances under which the adopting employer may or may  
                            not rely on the opinion letter (as set forth in section 7 of Rev. Proc                            
                            2017-41), and if the employer cannot rely on the opinion letter, the                              
                            possibility of filing for a determination letter in accordance with                               
                            section 12B of Rev. Proc. 2020-4?                                                                  (106) 
                                                                                                                      
 g.  Does the plan give the employer the option to select total                                                               
    compensation?                                                                                                             
                                                                                                                              
                                                                                                                               (107) 
 
                                                               10 of 10