Good Faith Amendment

Hi, 

For plans that are terminating should the Plan sponsor complete the good faith amendment ( SECURE 2.0 and CARES)? what if they have not done the amendment? 

Thank you. 

The plan has to be in compliance with all laws and regs when terminating. If they haven’t signed an up to date termination package, they shouldn’t terminate. 

45 minutes ago, Bill Presson said:

The plan has to be in compliance with all laws and regs when terminating. If they haven’t signed an up to date termination package, they shouldn’t terminate. 

They will need to have the amendment completed and then proceed with the plan termination or can they do this simultaneously? by when should they have the GFA completed? is there a deadline?  

We do all the plan termination resolutions and amendments simultaneously and then proceed with distributions. Perhaps it can be done differently.