PPA Restatement for Sungard Volume Submitter Docs

[Susan S.]

We restated our clients' Sungard volume submitter plan documents in April 2010 (EGTRRA restatement) and submitted each of them to the IRS for a letter of determination. I received an email from Sungard about a PPA restatement by January 31, 2012. I'm confused about whether or not this applies to our plans. Surely we would not need to submit for another LOD this soon.

[Guest Sieve]

Sungard must go to the IRS by 1/31/2012 for review/approval of its mass submitter document for the PPA Restatement, which the IRS will approve in early 2014, with a restatement period from early 2014-early 2016. That's the 6 year cycle. If you use Corbel to process a VS document in your name (so that you can use it for your clients), then you have to climb on board by 10/31/2011 so that the train doesn't leave without you. (The cycle is 2 years for the sponsor fo the mass submitter (Corbel) to prepare the document, 2 years to deal with the IRS before receiving approval, & then 2 years for individual employers to adopt.)

[Susan S.]

Sieve, thank you very much for the clarification.

[Santo Gold]

Sungard must go to the IRS by 1/31/2012 for review/approval of its mass submitter document for the PPA Restatement, which the IRS will approve in early 2014, with a restatement period from early 2014-early 2016. That's the 6 year cycle. If you use Corbel to process a VS document in your name (so that you can use it for your clients), then you have to climb on board by 10/31/2011 so that the train doesn't leave without you. (The cycle is 2 years for the sponsor fo the mass submitter (Corbel) to prepare the document, 2 years to deal with the IRS before receiving approval, & then 2 years for individual employers to adopt.)

Sieve - that is informative, but can you clarify by what is meant by "climbing aboard by 10/31/2011"? Does the 10/31 deadline apply to plan sponsors who apply for a determination letter for their specific plan, or is this more, for example, for a TPA firm that uses a Corbel document but has the document in their name? If the latter, what is it that must be signed, sealed and delivered by 10/31?

Thanks

[Jim Chad]

Since time is running out and I just did this, I am going to answer this.

I want to offer the Corbel adoption agreement style Volume Submitter to my clients again , next cycle (2014-2016). Also, I want to be able to adopt for my clients all required amendments. This way, I don't have to worry about EVERY one of my clients signing on time.

To do this, I went on line, filled in some form and paid $900 from my credit card. This is the IRS filing fee for 3 docs, Money Purchase Pension, Profit Sharing and 401(k). Corbel did not charge me, because I am already using their docs.

Next, I got an email with a power of attorney and some other things that need to be signed and sent back by 10-31-11. When you fax the signed forms back, be careful to check that they went through. Somewhere I got the wrong number. When I called it to test it, I got a voice mail. So I had to call and get another fax number.

[Guest Sieve]

The latter is what I'm talking about. So, 10/31 is Corbel's internal deadline if you want them to submit a plan to the IRS plan for approval in your name for adoption by your clients in the next round of restatements (2014-2016). Corbel's deadline to file with the IRS is 1/21/2012. So, if you are using Corbel to make your plan document submission, you must compelte their requirements by 10/31--Jim Chad did it online, apparently. (If you are submitting your own document yourself to the IRS for approval to market to your clients, then the IRS deadline to submit for an opinion letter is 1/31/12.)

[Peanut Butter Man]

Erisafile has a chart on their website comparing the various plan document providers. I'm using it to compare pricing before we decide to renew. Chart is at http://www.erisafile.com/ppa_restatement_fees.pdf