The agency will accept determination letter applications for hybrid plans for a certain period and for merged plans on an ongoing basis.
Tag: retirement plan documents
The web page provides information for retirement plan sponsors who have individually designed retirement plan documents but want to adopt a pre-approved prototype or volume submitter plan document.
The complaint argues defendants violated ERISA duties by reinterpreting plan language in a conflicted manner aimed at reducing employer costs.
In general, the Required Amendments List includes statutory and administrative changes in qualification requirements for individually designed retirement plans that are first effective during the plan year in which the list is published.
The IRS notes that Rev. Proc. 2017-41 modified the pre-approved letter program by combining the master & prototype and volume submitter programs into a new opinion letter program.
A retirement plan consultant and an ERISA attorney offer tips for setting up, maintaining and following retirement plan documents.
When the IRS ended its determination letter program, it said it anticipates making exceptions based on program capacity to work on additional applications, and the need for rulings in certain areas.
A plan sponsor using pre-approved plan documents to restate a plan for the plan qualification requirements included on the 2012 Cumulative List will be required to adopt the plan document by April 30, 2020.
The agency began issuing these lists when it ended the determination letter program for individually designed retirement plans.
Following the IRS' curtailment the determination letter program for retirement plan sponsors, McDermott Will & Emery is releasing an opinion letter and operational review program for individually designed plans.
Generally, the overall effective date for 403(b) pre-approved plans are plan years beginning on or after January 1, 2010, but this raises issues for certain plan sponsors.