LRM #94 - Text of Rev. Proc. 2011–49: Opinion and Advisory Letters for Pre-Approved Retirement Plan Documents

[buckaroo]

I recently read the new regulations and it appears that for prototype plans:

(1) You must now name the allocations groups in the plan document

(2) The restriction on the number of groups has been lifted.

Has anyone read this? Does anyone agree?

[Tom Poje]

for an upcoming ASPPA webcast

Restating Plan Documents for PPA

and Revenue Procedure 2011-49

When: Thursday, November 3 from 2:00 p.m. to 3:40 p.m. ET

one of the highlights says:

Attendee Takeaways:

Cross-tested prototypes will no longer have a limit on the number of allocation rates, but new questions exist as to the availability of individual participant by participant rate groups.

[buckaroo]

Tom,

Were there any conclusions from the 11/3 webinar? Are individual rate groups permitted?

[John Feldt ERPA CPC QPA]

It's unclear. The PPA documents will be reviewed by the IRS, and unless the IRS says something before then, the document providers will find out once the IRS reviewers respond. I assume the providers will still place text in their document that allows a checkbox for each participant being in their own allocation rate classification.