DB restatements

[JAY21]

I can't remember when the Volume Submitter DB restatement cycle begins though I think it is in 2010. Anyone know ?

[Guest Deflector]

I believe you are correct and it starts in 2010. However, I am not an attorney. This is what my attorney has told me.

[John Feldt ERPA CPC QPA]

If your DB plan is an individually designed plan, and you want IRS reliance on the plan's language (meaning you want a D letter), then your restatement is (or was) required based on the last digit of the sponsor EIN, with several exceptions. Take a look at Rev. Proc. 2007-44 for those details. EINs ending in 1 or 6 generally had a deadline of 01/31/2007, 2 and 7 had until 01/31/2008, and so on. If you don't want a D letter, you do not need to restate. However, that excludes you from some of the things allowed under EPCRS (I think), and you are breaver than me to not want IRS D letter reliance.

If your DB plan uses a pre-approved document, such as a prototype, then the EGTRRA restatement window will open sometime around February 1, 2010. To compare, the DC window was to open around 01/31/2008 and the IRS actually opened it on March 31, 2008.

http://www.irs.gov/retirement/article/0,,id=146977,00.html

If your firm is a document sponsor for a DB prototype, you should be listed here:

http://www.irs.gov/pub/irs-tege/egtrra_listdb.pdf

[JAY21]

Thanks for the good info.