The IRS has posted on its website: Retirement Plan FAQs regarding Governmental Plan Determination Letters. The FAQs are an attempt by the Service to answer some of the ongoing concerns practitioners have had in the governmental plans determination letter process. One of these areas of concerns has to do with plan documentation which is discussed by the Service in this paragraph:
The Service recognizes that governmental plans may have no single cohesive plan document available. The Service is willing to work with a plan sponsor whose plan document consists of documents from various sources and who is unable to submit a restated plan, provided that the sponsor can submit selected material in an organized manner so that Service reviewers can readily determine the applicable plan language.
See also Q & A 3:
What if the plan has not been timely amended and has never received a determination letter or received one a long time ago in the 1970’s?Answer: If a plan has been timely amended, it can submit a request for a determination letter without proof of all amendments since its inception, see Q & A 2. above. However, if a plan has not made amendments timely, it should be submitted under the VCP program. . .
See also this previous post here regarding governmental plans.