Liz Hallam

Austin - don't be ashamed think it was Kelsey Mayo (ARA) who mentioned in an article.

Look on page 63 of final regs - real clear - good faith until 1/1/2027. Specifical says administrative transition period IS NOT EXTENDED.

Much thanks to you and Lois - it certainly makes all of our lives much easier. You guys can't retire EVER!

@Paul I - the dates I put in there were based on conversations with IRS folks - nothing in writing. Obviously the date will be based on when most of the mass submitter have received the e-mail telling them they are OK.

Tom - the 2017 date is correct. That first time of IRS approval on 403(b) documents. Cycle 2 plan documents are undergoing IRS review currently. IRS has indicated that all documents should have the approvals by 11/30/24 with anticipated restatement start period to commence 1/1/25. The Cycle 2 period will be two years (don't look for extension). If your client is using a TIAA document, that is the latest letter.

ASC offers pre-approved governmental defined benefit. Contact them directly. You may want to also reach out to the other mass submitters (e.g. Relius, FT William, Datair, Ascensus

OP should reach out to Equitable (product area). This document has been updated as required since 1986 (which may have been the TEFRA, DEFRA REA version depending upon the time). Blank copies are available to those clients who "misplaced" their original copies.

FIS/Relius is not the only mass submitter document, ASCi govermental PS document provides same provision and imagine several other mass submitters do. If you used a mass submitter for your pre-approved plan, check with your provider.

"PS-58" costs are imputed income - not cash income - there's nothing to distribute. It's a reporting amount dependent on how participant takes insurance contract. At death, no "basis" rather amount "ar risk" (pure death benefit) is received by beneficiary income-tax free.

rocknrolls2 was correct - the trust requirement was added after Orange County, CA (not just the City of Long Branch) filed for bankruptcy. All kinds of stories how judges' accounts were attached because in bank accounts (with high interest rates). Interesting because City of Bridgeport, CT declared bankruptcy before that and no Congressional action. Custodial accounts and annuities satisfy requirements of 457(g). It was not providers who required it was Congress.

Large Recordkeepers do for those plans where they hold the assets which makes sense. As you look at the list, eliminate those firms and concentrate on TPAs. Know there are firms that will do for a fee (paid from plan assets).

Bill - that's for mass submitters. This goes back to old submissions (individual letters). You notice I said anticipates for Cycle 3 - depends on status for mass submitters (some are still in negotiations. That's OK because we'll have lots of interim amendments with our restatements.

IRS anticipates window opening on 8/1/20 and will close 2 years later (7/31/22). Just a few months late.