EPCRS - slight changes

[John Feldt ERPA CPC QPA]

http://www.irs.gov/pub/irs-drop/rp-07-49.pdf

Main item to note (for me): For failure to adopt required amendments timely, they really want the appendix F used "as is" (Appendix F) from Revenue Procedure 2006-27.

[Peanut Butter Man]

I caught the bit about Appendix F on the Pension Protection Act Blog - http://www.qualifiedpensionconsulting.com/ppablog.

I had problems following the rest of it. Is the IRS saying that firms which did not file for a defined contribution opinion/advisory letter by January 31, 2006, can now file and pay the higher fee, but only if they have a GUST letter? What about new companies who were not around for GUST? Any help on understanding this Rev. Proc. is greatly appreciated. We signed on as a word-for-word adopter with one company, and now want to either switch to another company, or sponsor our own plan if we can't find a better plan.

[John Feldt ERPA CPC QPA]

I am not 100% either, but I will hazard a guess.

I think they are first reminding us that their goal is to provide approval letters with enough time to allow the users of these approved documents about 24 months to restate all of our clients. They are talking about the M&P plan documents - I think of these as the big national template document providers (like Sungard, Accudraft, etc. - pre-approved documents) or anyone who is qualified under their procedure to submit those kind of documents.

They also state that the applications for these opinion or advisory letters for these template documents will be reviewed in the order received. So, there will be some delay for any requests for approval for pre-approved documents that are submitted after the normal due date in the six-year cycle (which was 1/31/2006 for EGTRRA DC document providers). This applies to all late submissions for opinion or advisory letters made after January 31, 2006.

Maybe someone else on the board can correct me and elaborate further. This specific portion of this topic is probably better served in the Plan documents section.