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EGTRRA Cycle


Randy Watson
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According to Revenue Procedure 2009-36, individually designed gov't plans can elect to use Cycle E as their EGTRRA remedial amendment cycle. When submitting for a letter, I believe they would need to include plan document changes for Cycles C and D cumulative list changes. Does that mean the Cycle C and D cumulative list changes just need to be adopted by the end of Cycle E or should they have been adopted already? HELP!!!!

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Usually these government plans have extended deadlines for adopting plan language that complies with any new law changes. So until the plan restates, they need to comply with the adoption of any required language (interim amendments) based on such deadlines as they apply to government employer plan sponsors.

Then for the restatement, you have to adopt whatever is required from the cycle E cumulative list in order to submit in cycle E, but that probably can exclude any items that are not yet required to be adopted for a government plan sponsor.

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