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.
Tag: retirement plan documents
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.