What must an employer do before making an 11(g) amendment for a coverage failure?

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The correct answer is to identify the specific failure. This step is essential as it allows the employer to understand the nature of the coverage failure fully. Identifying the specific failure helps in determining the appropriate amendments needed to rectify the issues to ensure the plan complies with regulatory requirements.

Understanding the exact nature of the failure is critical because it informs the subsequent actions the employer must take, such as the type of corrective measures to implement in the plan and how they will communicate these changes to participants. Addressing the particular failure also helps ensure that the employer is targeting the correct issue, avoiding unnecessary amendments that may not resolve the compliance problems.

Other options, while potentially relevant to overall plan management, do not precede the necessary identification of the specific failure required for an 11(g) amendment. Conducting an employee survey or notifying plan participants may be beneficial at a later stage but are not prerequisites for addressing the compliance issue itself. Evaluating the financial impact might be part of the overall amendment strategy, but without initially identifying the specific failure, it's challenging to assess any financial ramifications accurately.

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