In a SPARK Institute press release, Goldbrum said the Institute outlined in its letter nine areas for consideration in developing a prototype document to meet its stated goals. According to Goldbrum, some of the key considerations include pre-approval of documents covering governmental 403(b) plans and church 403(b)(9) plans.
“The objective of our comment letter to the IRS is to help in the design of a pre-approved 403(b) plan program which is accessible to employers on a cost-effective basis, is easy to implement and maintain, and is understandable to non-retirement plans specialists,” he said, in the announcement.
The SPARK Institute also requested that the IRS postpone the compliance deadline for the written 403(b) plan document requirement so that employers could adopt an IRS-approved prototype document at the outset, rather than developing their own document that may later have to be revised in order to comply.
Last week SPARK filed a 13-page comment letter with the IRS asking for an extension of the effective date for compliance and guidance on the treatment of contracts and information sharing agreements (See SPARK Institute Wants Extension for New 403(b) Regs).