Full Version: 6-Year Cycle (Volume Submitter)
According to Rev. Proc. 2007-44 at section 18.01, it appears that volume submitters are required to be submitted by January 31, 2011. However, I have been hearing that the real deadline is April 30, 2010 according to more recent guidance. Could someone confirm that the date in 2007-44 was in fact move forward or that I am perhaps misreading that section? Again, this stuff is clear as mud! Many thanks!!!
It is confusing, but I think Section 18 has to do with the timing for document providers to submit the next generation of documents for approval.
Section 16 addresses the timing for employers to adopt the approved plans.
The deadline was published in Announcement 2008-23.
Section 16 addresses the timing for employers to adopt the approved plans.
QUOTE
.03 When the review of a cycle for pre-approved plans has neared completion (after approximately a two-year review process), the Service will publish an announcement providing the date by which adopting employers must adopt the newly approved plans. This will be a uniform date that will apply to all adopting employers. Depending upon the length of the review process, it is expected that this date will give virtually all employers approximately a two-year window to adopt their updated plans. For purposes of this revenue procedure, an adopting employer means an employer who satisfies the requirements described under section 17 of this revenue procedure.
.04 An adopting employer that adopts the approved M&P or VS plan by the announced deadline will have adopted the plan within the employer's six-year remedial amendment cycle. The announced deadline will be the end of the plan's remedial amendment cycle with respect to all disqualifying provisions for which the remedial amendment period would otherwise end during the cycle.
.04 An adopting employer that adopts the approved M&P or VS plan by the announced deadline will have adopted the plan within the employer's six-year remedial amendment cycle. The announced deadline will be the end of the plan's remedial amendment cycle with respect to all disqualifying provisions for which the remedial amendment period would otherwise end during the cycle.
The deadline was published in Announcement 2008-23.
QUOTE
Deadline for Employer Adoption of EGTRRA-approved Defined Contribution M&P and VS Plans
An adopting employer whose plan is eligible for the six-year remedial amendment cycle under section 17 of Rev. Proc. 2007-44 and that adopts an EGTRRA-approved M&P or VS defined contribution plan by April 30, 2010, will have adopted the plan within the employer's six-year remedial amendment cycle. 1 The end of the plan's remedial amendment cycle with respect to EGTRRA and the changes in plan qualification requirements on the 2004 Cumulative List is April 30, 2010.
An adopting employer whose plan is eligible for the six-year remedial amendment cycle under section 17 of Rev. Proc. 2007-44 and that adopts an EGTRRA-approved M&P or VS defined contribution plan by April 30, 2010, will have adopted the plan within the employer's six-year remedial amendment cycle. 1 The end of the plan's remedial amendment cycle with respect to EGTRRA and the changes in plan qualification requirements on the 2004 Cumulative List is April 30, 2010.
QUOTE (Kevin C @ Oct 15 2009, 01:12 PM) 
It is confusing, but I think Section 18 has to do with the timing for document providers to submit the next generation of documents for approval.
Section 16 addresses the timing for employers to adopt the approved plans.
The deadline was published in Announcement 2008-23.
Section 16 addresses the timing for employers to adopt the approved plans.
QUOTE
.03 When the review of a cycle for pre-approved plans has neared completion (after approximately a two-year review process), the Service will publish an announcement providing the date by which adopting employers must adopt the newly approved plans. This will be a uniform date that will apply to all adopting employers. Depending upon the length of the review process, it is expected that this date will give virtually all employers approximately a two-year window to adopt their updated plans. For purposes of this revenue procedure, an adopting employer means an employer who satisfies the requirements described under section 17 of this revenue procedure.
.04 An adopting employer that adopts the approved M&P or VS plan by the announced deadline will have adopted the plan within the employer's six-year remedial amendment cycle. The announced deadline will be the end of the plan's remedial amendment cycle with respect to all disqualifying provisions for which the remedial amendment period would otherwise end during the cycle.
.04 An adopting employer that adopts the approved M&P or VS plan by the announced deadline will have adopted the plan within the employer's six-year remedial amendment cycle. The announced deadline will be the end of the plan's remedial amendment cycle with respect to all disqualifying provisions for which the remedial amendment period would otherwise end during the cycle.
The deadline was published in Announcement 2008-23.
QUOTE
Deadline for Employer Adoption of EGTRRA-approved Defined Contribution M&P and VS Plans
An adopting employer whose plan is eligible for the six-year remedial amendment cycle under section 17 of Rev. Proc. 2007-44 and that adopts an EGTRRA-approved M&P or VS defined contribution plan by April 30, 2010, will have adopted the plan within the employer's six-year remedial amendment cycle. 1 The end of the plan's remedial amendment cycle with respect to EGTRRA and the changes in plan qualification requirements on the 2004 Cumulative List is April 30, 2010.
An adopting employer whose plan is eligible for the six-year remedial amendment cycle under section 17 of Rev. Proc. 2007-44 and that adopts an EGTRRA-approved M&P or VS defined contribution plan by April 30, 2010, will have adopted the plan within the employer's six-year remedial amendment cycle. 1 The end of the plan's remedial amendment cycle with respect to EGTRRA and the changes in plan qualification requirements on the 2004 Cumulative List is April 30, 2010.
OK, that makes sense. Thank you very much.
Note that many document providers are not writing PPA amendments for GUST docs. So to amend for PPA by 12-31-09 means restating for EGTRRA by 12-31-09 and using that tack on amendment for PPA.
QUOTE (Jim Chad @ Oct 16 2009, 08:13 PM)
Note that many document providers are not writing PPA amendments for GUST docs. So to amend for PPA by 12-31-09 means restating for EGTRRA by 12-31-09 and using that tack on amendment for PPA.
That was going to be my next question, but I have a couple more related questions.
1. Is 12/31/09 the deadline for calendar year DC plans only? Non-CY plan amendments due by the end of their 2009 PY?
2. Is a model DC PPA amendment available from the IRS? I would doubt it.
3. If we have to prepare an amendment, is the QOSA the only provisions that needs to be addressed for DC plans? I would be surprised if that is the case.
Thank you again and welcome to Monday.
This is a "lo-fi" version of our main content. To view the full version with more information, formatting and images, please click here.