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in my case, since people knock the 'L' out of me, it's anthro-po-je

Here we go again. ASPPA conferences are recorded. For at least the last few years, those recordings are mailed to each attendee. I have attended the ASPPA annual conference, including the DC Q&A sessions, for more years than I care to mention and have never heard an IRS representative say that the only mid-year amendments allowed for a SH plan are the two situations referenced in Announcement 2007-59 (Roth and modifying hardships). Recently, I pulled out my conference DVD from 2011 and typed up the IRS comments on the questions where some claimed this was said. Since the IRS has supposedly said this repeatedly, I challenge someone to provide either a transcript or a written Q&A response from a session where the IRS actually said what is claimed. Here is a copy of my prior post with the transcript of the IRS statements at the 2011 ASPPA annual conference: I pulled out my 2011 annual conference DVD. The SH mid-year amendment questions, 39 and 40 start at 1:18:20 on the clock. The response to the first question about changing deferral eligiblity was Ilene mentions something about her recollection being the only amendments are Roth and Hardship. I took that as a reference to the cited guidance on amendments. The next question is another mid-year question. The response is Now I'm being told the IRS said last week that the ONLY mid-year amendments allowed to safe harbor plans are adding Roth and expanding hardships to funeral expenses. I see changing from saying we are sticking with the published guidance to saying no amendments other than those addressed in Annoucement 2007-59 are allowed is a "major" change. <end of prior post> And, here is the text from Announcement 2007-59: Nothing in the Announcement says these are the only changes that can be made. It says that these two particular mid-year changes are OK. Many have asked for additional guidance. The IRS has consistently said at the conferences I've attended that they will not be issuing additional guidance.