PPA/436 amendment signed in 2009. Need to sign another one?

[katieinny]

An employer signed a lengthy PPA amendment that included the 436 language back in 2009. I was just reminded that there has been an extension on the 436 amendment until the end of 2013. It seems weird to me that this thing has been extended year after year. Or am I missing something? Is there new 436 language that needs to be adopted and the employer needs to sign another 436 amendment?

[Lou S.]

I thought there was some clarification of the model amendments in 2012 and if you adopted them in 2012 based on IRS published guidence you are fine and don't need to re-adopt them. If you adopted them in 2009, you may want to reveiw the amendment against the final IRS model amedment to see if your amendment is up to snuff so to speak.