Qualifying as a Church Plan and the 403(b) Plan Document

Q. A Christian broadcasting station wants to set up a 403(b) plan as a church plan. However, they don’t really qualify for designation as a church plan; nor are they a qualified church control organization (QCCO). Do they need a copy of the plan documents to inquire as to whether they meet the qualifications for a church plan?  

A. No, the 403(b) plan document is not one of the items that they need to submit in order to secure approval as a “church” or as an “association of churches.” This would be step two, adopting the plan after approval as a church!