I am familiar with significant dates for DC plan updates, but I've run across a couple of DB plans that have dates in the mid to late 80s. Were they not required to do anything in '94?

Probably the reference is to changes from GATT, passed in December 1994. This, along with other legislation in 1995, 1996, 1997, etc. has come to be known as "GUST", primarily because the IRS has given a remedial amendment period for all of them.

The most frequently discussed DB-related item from GATT was a change in the way minimum lump sums (actuarial equivalents) are calculated. This item will generally not apply to DC plans.

So, are you saying that a DB document that was signed prior to 1990 is in compliance? I believe that DBs need to be restated for GUST (true?), but I'm wondering when the last restatement period was for DB plans prior to GUST. Or is it possible that DBs don't go through restatements en masse like DC plans do?

All Plans should have been amended to comply with TRA '86 and later tax laws. If I recall, the remedial amendment period for calendar year plans ended on December 31, 1994 and the Plan had until March 31, 1995 to be submitted to the IRS.

Among other things this amendment would have included the compensation limit of $150,000, the changes in social security integration and the required rollover language.

I think Richard has the correct dates.
Perhaps it would be helpful to distinguish between an effective date and a signature date. In the case of TRA86, the effective date was (probably) January 1, 1989, but this remedial amendment period did not end until December 31, 1994 (CY plans). I'm still not sure if the original question is referring to effective date or signature date.

Yes DB plans need to be amended for GUST.

The actual last date to execute a document depended on the date of approval of the prototype or volumne specimen document. We restated plans up until August 1995 on a prototype that was approved in August 1994. Of course, these had to be restatements of plans that adopted that prototype no later than August 30, 1994. The effective date of the restatement was 1989.

So, basically, the same restatement periods applied for DBs as DCs over the past 15 (give or take) years. If I came across a client with a DC plan that was signed in 1985 (and nothing since), I would be worried. It sounds like I should have the same sinking feeling now that I've found a DB plan with a similar date.

Yes, if the plan has an effective date in 1985, with nothing later, that will be a problem, failure to properly and timely update the document for statutory changes.

You might want to check this http://www.benefitslink.com/qa_columns/pla...cts/index.shtml for advice on what to do in this case.

In general, remedial amendment periods will be the same for DB plans as for DC plans.