Under the new regime, when must a sponsor of an individually-designed plan do plan amendments?

[Peter Gulia]

An employer has an EIN ending in 6. Its ESOP has a determination letter dated April 2014. So far, no one offers a useful prototype or volume-submitter document to restate the plan on.

If concerning an individually-designed plan an Internal Revenue Code change makes a tax-qualification amendment necessary (and Congress's Act doesn't provide a special remedial-amendment period), when must the plan's sponsor complete the amendment?

According to the regulations' ordinary remedial-amendment period without an extension or other administrative grace?

[Peter Gulia]

I understand that a Cycle A plan may do a remedial amendment now (through January 31, 2017).

But what happens after 2017?

Must a plan's sponsor do a plan amendment for every year for which there was a plan change?

[GMK]

Until the prototype and VS ESOP documents become available, we have to keep current on required amendments ... same as before, not? When they do become available, supposedly by 2017 or 2018, we will follow whatever procedure is then in place for adopting one. Are there other realistic options?

[Peter Gulia]

GMK, thank you for confirming my thinking.