The two items that may require an amendment relate to difficulty of care payments treated as compensation for 415 limits, and the application of cooperative and small employer charity pension plan rules.
“There’s a gap in the market where the solo adviser or small office is trying to create their own marketing, sales, and service process documents,” says Sharon Pivirotto.
The March 31 deadline for 403(b) plans has been extended to June 30; the April 30 deadlines for DB plans have been extended to July 31.
Revenue Procedure 2019-39 sets forth a system of recurring remedial amendment periods for correcting form defects in 403(b) individually designed plans and 403(b) pre-approved plans occurring after the initial remedial amendment period ends on March 31, 2020.
New FAQs offer information about when retirement plan sponsors can adopt pre-approved plans and when determination letters are issued.
The complaint stems from defendants’ alleged refusal to pay post-termination benefits to the plaintiff—and a sizable similarly situated class of would-be beneficiaries—pursuant to terms and definitions in plan documents.
When the agency ended its determination letter program, it said it would publish a list of required amendments for individually designed retirement plans to maintain their qualified plan status after October 1 of each year.
The IRS has extended the deadline for submitting on-cycle applications for opinion letters for pre-approved defined contribution (DC) plans for the third six-year remedial amendment cycle to December 31, 2018, from October 1, 2018.
Plan sponsors have a fiduciary duty to operate in accordance with the plan document, but an ERISA attorney shares common cases when mistakes are made.
The agency ended its determination letter program effective in 2017, but said it will measure the need for exceptions in a variety of ways including annual input from the Employee Plans (EP) community.
The IRS extended the period to adopt an approved plan document to April 30, 2020, from January 31, 2019.
The 2017 RA List is light on items.