New plans after year end, sure, but...

If I recall, one of the provisions of the SECURE Act was that plan sponsors could adopt a new 2020 plan up through the date of their tax filing deadline next year.

(presume calendar year for the plan and client's tax filing, please)

Some sponsors may want to freeze their plans now ahead of folks getting into 1000-hour range for benefit accrual.

If there was no plan, I'd think the sponsor could start a new plan up at some point in 2021. 

But that's not the exact same fact pattern as the sponsor un-freezing an existing plan in 2021 for the 2020 year before their tax deadline.

I wouldn't have to get a decision from clients by 12/31 to un-freeze, would I?  (I hope the alternative isn't to adopt a new plan and merge them.)

Thanks....

I think they have until 3/15/21 if a 412(d)(2) election is done.  Anyone disagree?