Required Plan Document Changes

[Guest dietpepsi]

I'm not sure why Chang, Ruthenberg and Long indicate there are required changes for governmental 457(b) plan documents. These plans do not have a RAP.

http://www.seethebenefits.com/showarticle.aspx?Show=3434

Also, some of the required changes appear to be optional in my opinion. What am I missing?

Thoughts?

Thanks

[John Feldt ERPA CPC QPA]

The Pension Protection Act of 2006 (and other changes in law). Some of these provisions are optional, some are not.

1. Any 457(b): Change in definition of unforeseeable emergency, deferring from post-termination pay, QDRO

2. Gov 457(b): Direct rollover to Roth, 402(f) notice timing changes to 180 days, direct rollover for non-spouse beneficiary, health and long-term care distributions, hurricane relief.

[Guest dietpepsi]

Thanks. Since there is not a remedial amendment period for 457(b) plans, is there a certain time by which these changes need to be made to the plan document? Are people doing it now or waiting until 2011 or later?

Thanks

Suzie

[John Feldt ERPA CPC QPA]

PPA indicates amendments are not required until the end of the 2009 plan year, or the last day of 2011 for a government plan. The IRS hasn't issued guidance related to 457(b) plans since the time they released the final 457(b) regulations. Without any additional guidance, I'd recommend at least the 2009/2011 deadlines.