Cash Balance - PPA Restatements

[msmith]

What is everyone using for the PPA restatement effective date? Are you going back to the original effective date because there was no IRS reliance on the prior document?

Any comments are appreciated.

 

[CuseFan]

Generally you use the first day of the current (or possibly subsequent) plan year, because the document should have embedded effective dates for various PPA provisions.

[G8Rs]

If you never received a determination letter on the plan, I'd suggest using a retroactive effective date because you have no reliance on the prior terms. I agree with the current effective date approach when you are restating a plan that already has reliance (either a determination letter or reliance on pre-approved plan).

[ERISA1]

On 11/9/2018 at 10:49 AM, CuseFan said:

Generally you use the first day of the current (or possibly subsequent) plan year, because the document should have embedded effective dates for various PPA provisions.

I have  found that PPA documents don't include adequate provisions to clarify effective dates for specific laws or individual client designs. My sponsors document only says it is intended to to satisfy the requirements of the 2012 Cumulative List.  Is anyone doing more than relying on general provisions in the document? 

Thanks