Jump to content

Cycle 3 deadline.... Date Confused


Basically

Recommended Posts

In announcement 2020-07 there is this passage:

Deadline for Employer Adoption of Pre-approved Defined Contribution Plans
The end of the third six-year remedial amendment cycle for pre-approved defined contribution plans is January 31, 2023. An adopting employer whose defined contribution plan is eligible for the six-year remedial amendment cycle and who adopts, by July 31, 2022, a newly approved plan, will be considered to have adopted the plan within the third six-year remedial amendment cycle.

so... Jan 31, 2023 or July 31, 2022?  I don't get the need for 2 separate dates.  

If I have an existing plan and we need to restate the document to comply with Cycle 3  it says above "The end of the third six-year remedial amendment cycle for pre-approved defined contribution plans is January 31, 2023"  which I am taking to say you need to restate by 1/31/23.  Or do I need to have them restated by July 31, 2022? 

What is the IRS is trying to convey?  What am I missing?

Link to comment
Share on other sites

I think restatements must be adopted by 7/31/2022. I'm not sure but I think it's the sponsors of those plans (not adopting employers) that have until 1/31/2023 to make corrections to their documents, but I could be wrong.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

Link to comment
Share on other sites

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now
×
×
  • Create New...