any requirement of this subsection if, before the issuance of the guidance under subparagraph (A), the employer or pooled plan provider has complied in good faith with a reasonable interpretation of the provisions of this subsection to which such guidance relates. (5) Model plan The Secretary, in consultation with the Secretary of Labor, shall publish model plan language which meets the requirements of this subsection and of paragraphs (43) and (44) of section 3 of the Employee Retirement Income Security Act of 1974 and which may be adopted in order for a plan to be treated as a plan described in paragraph (1)(B). . (2) Conforming amendment Section 413(c)(2) of such Code is amended by striking section 401(a) and inserting sections 401(a) and 408(c) . (3) Technical amendments (A) Section 45E(d)(3)(A) of such Code is amended by striking effective and inserting effective with respect to the eligible employer . (B) Section 408(c) of such Code is amended by inserting after paragraph (2) the following new paragraph: (3) There is a separate accounting for any interest of an employee or member (or spouse of an employee or member) in a Roth IRA. . (b) No common interest required for pooled employer plans Section 3(2) of the Employee Retirement Income Security Act of 1974 ( 29 U.S.C. 1002(2) ) is amended by adding at the end the following: (C) A pooled employer plan shall be treated as— (i) a single employee pension benefit plan or single pension plan