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Posted

Any insight on whether an extension is on the way. My clients are being bombarded with form documents (many of which are outdated and incorrectly drafted - one actually refers to the "exclusion allowance" and the 402(g)(8) limitation - these documents are being distributed by national consulting companies, REALLY!!). The employers are not being advised of the obligation to make deferrals available to union employees, and those that are, cannot comply in a timely fashion. Small non-profits do not have the manpower or budgets to hire fancy law fims to interpret these documents. I think that the purpose of the regulations was a good idea, but the implementation requires more time and education. An extension was granted for 409A - which was much more complex. It goes without saying that an extension is necessary. Bob Architect, are you reading this?? Also, for those of you who missed the videos, Bob's videos on You Tube are great!!

Posted

Maybe the IRS thinks that giving ground again in a culture that has a tradition and mentality of noncompliance would be a never ending process. Only the discipline of the deadline got us this far. An extension will have us in the same place next year. A lot of plans will be noncompliant at the deadline no matter what the deadline is. Being in violation is a motivation.

Posted

They did say about two weeks ago that they were considering an extension or a remedial amendment program, but I'm not aware* of anything since then.

*And my knowledge is limited; I just happened to remember seeing this. I try to stay away from 403(b)s.

Ed Snyder

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