IRS Updates Procedure for Opinion and Advisory Letters

The Internal Revenue Service released Revenue Procedure 2011-49, on new requirements for sponsors of pre-approved plans seeking opinion and advisory letters that the plans' form is acceptable.

The procedure affects master and prototype (M&P) plans and volume submitter plans. It modifies and supersedes Rev. Proc. 2005-16. For M&P plans, the procedure makes several changes, such as revising some definitions, clarifying the effect of employer amendments, and changing areas not covered. For volume submitter plans, the procedure clarifies language on the 30-employer requirement and authority to make amendments to the plan.

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Revenue Procedure 2011-49 will appear in Internal Revenue Bulletin 2011-44 on Oct. 31, and is available here.

MIRA and SFS Form Partnership to Pool Resources

Millennium Investment and Retirement Advisors (MIRA) and Southeastern Fiduciary Services (SFS) have formed a partnership. 

As part of the partnership, the resources of the two firms will be pooled to provide more technical expertise and enhanced services to their retirement plan clients.

SFS, founded by Bert M. Carmody, CPA, CIMC, AIF, provides independent fiduciary, operations, and governance support to retirement plan sponsors.  MIRA, founded by Rick Canipe, EA, provides investment consulting and fiduciary services to retirement plans. 

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SFS will continue to offer its ERISA fiduciary services and become a technical resource to MIRA on ERSIA retirement plan operational, compliance, and governance issues. Carmody will serve as a MIRA principal in the Atlanta area and direct ERISA consulting activities in the Southeast. 

Canipe stated, “This is an exciting time for two strong niche players to partner in solving the complex fiduciary and ERISA issues that confront retirement plan sponsors. The retirement plan industry benefits not from mergers where identities and skills disappear in the guise of efficiency or consolidation, but by partnerships of focused, niche firms where strengths are leveraged. The bar has been raised and these two firms will help our clients get over that bar and run their plans successfully.” 

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