Prototype DB Plan Document

[emmetttrudy]

A plan sponsor has adopted a pre-approved Prototype DB Document. Are they on a 5 year cycle or 6 year cycle?

[John Feldt ERPA CPC QPA]

Pre-approved plans are on the 6-year cycle. The current DB 6-year cycle ends/restarts sometime in early 2016, not before 2-1-2016.

They can generally rely on the opinion letter assigned by the IRS to that prototype. If they do a "no-no" in some of the document selections, they can lose reliance and be in the 5-year IDP cycle. For example, if they wrote cash balance plan provisions in the "other" boxes somehow, or if they amended the plan to add cash balance provisions.

See Rev roc 2007-44, Part III and IV. http://www.irs.gov/irb/2007-28_IRB/ar12.html

edit: typo

[John Feldt ERPA CPC QPA]

Here's a chart that may have some use, but the 403(b) restatement column is just a fantasy, ... for now ...

6_year_cycle_with_403_b__Guess.pdf