I recently found some IRAs that were opened without IRA plans. This means that customers did not receive a custodial agreement or a 5305-A at account opening. Some of the accounts are set up as POD rather than beneficiaries with percentages. Have we broken rules or laws due to not providing the named documents? Do we need to just close the accounts and open up plans and do an internal transfer of the funds so that customers can get all updated and corrected IRA disclosures? If not, do we just try to maintenance the accounts so they show beneficiaries rather than POD or is that not necessary? They did receive TIS (a CD TIS, but they basic information was there).
Any help is welcomed.
Thanks!

I think you need to engage both legal counsel and a tax professional to determine what you have here. Are they or are they not even IRAs would be the first step.

The product states they are IRAs

I can call a skunk a squirrel and I still have a skunk. It is not want you intended to do - it is what you did from a legal standpoint. Engage the professionals.

Thanks