Lori H Posted September 15, 2014 Share Posted September 15, 2014 If a small 403(b) terminates and liquidates by 12/31/14, is PPA restatement required? Thanks Link to comment Share on other sites More sharing options...
John Feldt ERPA CPC QPA Posted September 15, 2014 Share Posted September 15, 2014 The IRS has not yet opened the restatement window for 403(b) plans, so a PPA restatement is not required, nor is it even available, generally speaking, loosely equating restatement to mean a requirement under a remedial amendment period to maintain a plan's relaince on its written plan language. 401(k)/PS/MP/Target plans are in the PPA restatement period now (ends 4/30/2016), but not the 403(b) plans. Restating a 401(k)/PS/MP/Target plan gives the plan reliance on the pre-approved PPA IRS opinion/advisory letter that they provide to the document sponsor. No 403(b) plans have opinion or advisory letters yet (nor can they get one yet). Any "restatement" by a 403(b) plan is just an amendment with no reliance. Maybe the IRS will open the 403(b) restatement window 3 years from now? Link to comment Share on other sites More sharing options...
Lori H Posted September 16, 2014 Author Share Posted September 16, 2014 Thanks. Link to comment Share on other sites More sharing options...
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