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PPA opinion letters for DC prototype/volume submitter out yet?


Guest TaxedToDeath
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Guest TaxedToDeath

The IRS indicated on its website on 3/27/2014 that it expected to issue "most opinion and advisory letters for the latest round of pre-approved defined contribution plans on March 31, 2014." But so far, none of the TPAs I have spoken to have received their letters yet. Has anyone else received their opinion letters? :unsure:

http://www.irs.gov/Retirement-Plans/New-Two-Year-Period-to-Adopt-Restated-Pre-approved-DC-Plans

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A follow-on question: If a big bank, insurance company, or recordkeeper in early May gets the letter on its volume-submitter document, how much time does the institution take to program the computers and set up the services to be ready to process a restatement on the revised documents?

(I ask this because a client wants to do its restatement as soon as possible. The employer made ONE modification to state a provision not in the volume-submitter document, and cannot get the IRS's determination until it presents the modification as done on the again-restated plan.)

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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