457 plan document compliance - restatement

[Tom]

We do not work with 457 plans but a financial advisor who refers to us asked me about a 457 plan that they took over management of - specifically what is the plan document restatement cycle like for these plans?  Was there an April 2016 PPA deadline like 401(k) plans?  Or something else?  When was the last required restatement deadline?

Thank you,

Tom

[Carol V. Calhoun]

There isn't one.  For governmental plans, section 457(b)(6) permits them to correct at any time before the first day of the first plan year beginning more than 180 days after the date of notification by the IRS that there is a problem.  There is limited ability to use VCP-like procedures for nongovernmental plans. See Rev. Proc. 2019-19. However, aside from that, there is no formal statement of when deadlines might be, or procedure for retroactive amendment.