(b)lines Ask the Experts – 2013 “Gifts” from the IRS

December 24, 2013 (PLANSPONSOR (b)lines) – “I seem to recall a reader suggesting  a “wish” list to Santa last year in Ask the Experts. Did Santa deliver on any of the requests?”

Michael A. Webb, Vice President, Retirement Plan Services, Cammack LaRhette Consulting, answers:

You have an excellent memory, and Santa was two-for-three in terms of the requested “gifts” (see “Ask the Experts: “Gifts” for 403(b) Sponsors”). To summarize the article, Christmas list items for delivery by Santa were: the Internal Revenue Service (IRS) Prototype Program for 403(b) plans, revised Employee Plans Compliance Resolution System (EPCRS) guidance, and less guidance!

As for the first item on the list, the IRS did indeed deliver (no doubt, at Santa’s request) the long-awaited prototype program on March 28, 2013 (see “IRS Establishes Program for Preapproved 403(b) Plans”) albeit without an individual determination for individually designed plans (see “Ask the Experts: Plan Determination Letters”).

We, along with Santa, still eagerly await item two on the list, revised EPCRS program guidance, as it will contain post-403(b)-regulations guidance for 403(b) plan corrections. Perhaps it will be under the tree this year, or sometime in 2014.

Finally, in comparison to prior years, 2013 was light on guidance that would create additional administrative burdens for 403(b) plan sponsors. Thus, it is fair to say that plan sponsors’ Christmas wishes in this regard were satisfied.

Overall, not a bad batting average for Santa, in the Experts opinion! Happy Holidays to all of our readers!


NOTE: This feature is to provide general information only, does not constitute legal advice, and cannot be used or substituted for legal or tax advice.