Custom Plan Document Restatement

[khn]

Say an individually designed plan document was last restated effective January 1, 2011. They are supposed to restate every 5 years, which would have been January 1, 2016, but if they haven't they still have the option to move to a pre-approved document as long as they do it by April 30, 2017 - is that correct?

[Lou S.]

The PPA pre-approved deadline for DC plans was April 30, 2016

The PPA pre-approved deadline for DB plans has not yet been announced to my knowledge but to get the extended restatement period for a DB plan I believe you need an executed Form 8905 prior to the end of the 5 year restatement period.

[khn]

Thanks for your reply. I'm specifically wondering about IRS Announcement 2014-16 that says this extension is to facilitate a plan sponsor's ability to convert an existing individually designed plan into a current defined contribution pre-approved plan.

[Lou S.]

https://www.irs.gov/irb/2014-17_IRB/ar08.html

IRS announcement 2014-16 specifically lists 4/30/2016 as the date to adopt by. Where are you getting the 4/30/2017 date from?

[khn]

Sorry, i should have been more clear with my question. This is what's on the IRS webstite: April 30, 2017, is the extended deadline for any defined contribution pre-approved plan adopted on or after January 1, 2016, other than a plan that is adopted as a modification and restatement of a defined contribution pre-approved plan that had been maintained by the employer prior to January 1, 2016. This extension is to facilitate a plan sponsor’s ability to convert an existing individually designed plan into a current defined contribution pre-approved plan. See Notice 2016-3.

Hence my confusion..