In response to the IRS’ call in Notice 2012-25 to provide input on the retirement benefit items (and relative priority of such items) to be included on the 2012-2013 Guidance Priority List, an update to the Employee Plans Compliance Resolution System (EPCRS) and the prototype plan document program for 403(b)s were items three and four.
ASPPA recommends the IRS update and expand Revenue Procedure 2008-50 for qualified plan corrections, including additional flexibility to correct for employees who defer before becoming eligible under the plan terms, loan violations and 403(b) plan defects. It also suggested the IRS provide guidance about the new pre-approved 403(b) plan program and relief for hardship distributions for certain 403(b) contracts. The group said a program for individually designed 403(b) plans with a determination letter process would also be beneficial.
At the top of ASPPA’s list was additional guidance on permissible mid-year changes for safe harbor plans and an update of the interim amendment process.
ASPPA’s full recommended list is here.
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