Ask the Experts April 8, 2014

(b)lines Ask the Experts – Delay of Pre-Approved Plan Documents

April 8, 2014 (PLANSPONSOR (b)lines) – “Are we expecting vendor-provided 403(b) prototype documents anytime soon? I seem to recall from a prior Ask the Experts article that the deadline for submissions is at the end of this month.”

Reported by

Michael A. Webb, vice president, Retirement Practice, Cammack Retirement Group, answers:

You will likely need to wait a while longer for those vendor prototype documents to be released. Recently the Internal Revenue Service (IRS) issued Revenue Procedure 2014-28 (see “IRS Modifies Procedures for Pre-Approved 403(b)s”) which extended the April 30, 2014 deadline for prototype and volume submitter document submissions to the IRS to April 30, 2015. In addition, as the Experts indicated in their most recent Q&A on the prototype program (see “(b)lines Ask the Experts – Availability of IRS Approved Prototype Document”) once vendors complete their prototype applications and submit them to the IRS, it will take the IRS an indeterminate period to review and issue a favorable opinion letter. Thus it is not unreasonable to expect that IRS-approved vendor prototype documents may not be ready for at least another year or two at a minimum.

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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.