In its announcement, Diversified said that in response to the IRS’ request for written comments on the proposed program and sample language, it submitted comments requesting that the IRS add vesting schedules for employer contributions and certain church-specific provisions. In addition, Diversified suggested that the language in the proposed list of Required Modifications be clarified in order to address the needs of a diverse group of 403(b) plan sponsors.
Diversified’s concerns are similar to those of other providers and trade groups who raised the issue of vesting schedules and accommodating for plans with multiple vendors (see Trade Groups/Providers Comment on 403(b) Prototype Program and SPARK Offers Suggestions for 403(b) Prototype Program ).
The IRS issued the proposal for the prototype program in April (see IRS Releases Proposed 403(b) Prototype Document Program ).
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