Tom Poje

the latest on pre-approved documents

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Is anyone else finding the guidance a bit odd?  In the world of qualified plans, we've normally had a deadline by which a pre-approved plan sponsor must amend its plan and apply for a determination letter, and then a later deadline by which an employer must adopt the plan as approved by the IRS.  However, in the case of 403(b) plans, the IRS has announced the date by which employers must adopt a pre-approved plan, but not the date by which plan sponsors must update their plans.  Could a sponsor wait until March 31, 2020 to submit the plan, have employers adopt it before it was submitted, and have the employers protected?  But if so, what protection would the employer have in case the sponsor decided to give up on the application before it was approved?

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