RMD amendments

[PensionNewbee]

when were/are these required to be done?

[Guest jhm]

Qualified defined contribution plans under 401(a) generally must be amended by the end of the first plan year beginning on or after January 1, 2003. See Rev Proc 2002-29. Rev Proc 2003-72 extended the deadline to the later of the first plan year beginning on or after January 1, 2003 or the end of the GUST remedial amendment period. This does not extend the 12/31/03 deadline for sponsors of pre-approved plans. The deadline for defined benefit plans is delayed. DB plans do, however, have to be operated in compliance with the regulations. Note that Tripodi says that 403(b) and 457 plans do not have to be amended at all, although they also must be operated in compliance with the final regs.

[PensionNewbee]

what if the snap on amendment didn't include the final RMD amendments? The document provider we use didn't have that piece in the amendment when we did the snap on for this client. Now what?