Belgarath Posted April 14 Posted April 14 Is this even possible? I didn't think the IRS did any Advisory letters for "pre-approved" plans that early. Have NOT seen the actual document or IRS letter to confirm what the audit firm is saying...
Paul I Posted April 14 Posted April 14 This may help clarify things: "Announcement 2014–16 Issuance of Opinion and Advisory Letters for Pre-approved Defined Contribution Plans for the Second Six-Year Cycle, Deadline for Employer Adoption, and Opening of Determination Letter Program for Pre-approved Plan Adopters The Service will soon issue opinion and advisory letters for pre-approved (i.e., master and prototype (M&P) and volume submitter (VS)) defined contribution plans that were restated for changes in plan qualification requirements listed in Notice 2010–90, 2010–52 I.R.B. 909 (2010 Cumulative List) and that were filed with the Service during their second submission period under the remedial amendment cycle under Rev. Proc. 2007–44, 2007–2 C.B. 54. The Service expects to issue the letters on March 31, 2014, or, in some cases, as soon as possible thereafter."
Bill Presson Posted April 14 Posted April 14 I assume this is the letter for the PPA document and it’s possible they missed the C3 restatement. William C. Presson, ERPA, QPA, QKA bill.presson@gmail.com C 205.994.4070
Belgarath Posted April 15 Author Posted April 15 I believe this was for "regular" DC plans, not 403(b) plans. Have I got that wrong? Sorry if I didn't make it clear my inquiry was on a 403(b) plan.
EBP Posted April 16 Posted April 16 I believe the submission period for Cycle 1 403(b) pre-approved plans ended 4/30/2014 and opinion letters were issued on or around 3/31/2017, so no, it doesn't seem like a 2014 opinion letter would be correct.
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