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Governmental 401(a) plan document providers


Guest MDM

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Does anyone know of a prototype plan document provider that can provide a prototype for a governmental 401(a) defined contribution plan (or a template in prototype format for such a plan (i.e., with a basic plan document and adoption agreement), even if not pre-approved by the IRS)? Thanks for any assistance.

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  • 1 year later...

I have the same question but it does not have to be a prototype checklist formatted plan -- VS or IDP would be fine. Does anyone know of a document provider for governmental plans?

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Guest cbclark
I have the same question but it does not have to be a prototype checklist formatted plan -- VS or IDP would be fine. Does anyone know of a document provider for governmental plans?

I am not a Sungard Relius employee so I am not shilling for them, but they posted in a client newsletter last week that they have a governmental volume submitter plan option structured with an adoption agreement. I have not explored when it is available or the cost.

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There are not any prototype or volume submitter governmental plan documents. The IRS just started the program for them with the PPA DC documents. They are being submitted to the IRS shortly with approval expected around April 2014. I would expect most if not all of the major document providers to have governmental plans by 2014. I don't know if any of the document providers are planning on allowing interim adoption of their governmental plan documents after they are submitted to the IRS.

The Sungard newsletter probably dealt with signing up to sponsor their governmental plan. We signed up with our document provider a couple of weeks ago.

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Any governmental plan in existence right now, regardless of how their document looks, is an IDP plan - there is no automatic reliance. Any governmental plan currently using a pre-approved document that has an opinion letter for a prototype or an advisory letter for a vol sub, cannot actually rely on such letter. As an aside, this also applies to any church plan that is not electing to be covered by ERISA under 410(d).

The IRS will, for the first time, allow a pre-approved governmental plan defined contribution documents starting sometime in 2014 whenever the IRS releases all of the 2nd 6-year cycle (PPA restatement) pre-approval letters. No such option for non-electing church plans - all are IDPs - you can only submit a 5300 to get a D letter there.

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Guest cbclark
We checked with Sungard, and they said the government plan doc would not be available until 2014!! Whether that newsletter was accidentally misleading or whether it was a "trial balloon" I can't say.

Oh wow I didn't inquire, since calling for a quote for something I was not interested in seemed a waste of time, so I'm sorry for the incorrect/inadequate info in my post. If I am charitable I would guess "trial balloon" but it is bothersome that in the information there is no reference to 2014.............

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It's not that uncommon to see "prototype-formatted" documents for governmental plans.

I think one of the frequent posters here at benefitslink mentioned to me that they had created a pre-approved document (an IRS vol sub with and it had an advisory letter) but that document also allowed certain boxes to be checked for use with governmental plan sponsors - EXCEPT the basic document also stated that making such an election meant that the plan sponsor could not rely on the IRS advisory letter.

Sort of an IDP/Vol Sub hybrid document - pre-approved unless certain provisions are marked. Of course any Vol Sub document could be marked up in a way that takes it out of reliance.

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