"Today, a client sent me a package of what its recordkeeper labels 'your SECURE 2.0 Act Interim Amendment.' The package describes this as 'changes from your Cycle 3 qualified retirement plan.' BenefitsLink neighbors, I'd welcome your help so I learn some contours about a plan sponsor's uses of documents of this kind.

"Am I right in guessing that an interim amendment does not get an IRS imprimatur like the IRS opinion letter that results from an on-cycle review of IRS-preapproved documents? Am I right in guessing that an interim amendment -- even if the documents' designer built it from the IRS's Listing of Required Modifications -- does not get any IRS assurance?

"A user may not rely on the IRS opinion letter that accompanies an IRS-preapproved document unless the user makes no change beyond those expressly allowed within the document or by an IRS Revenue Procedure about preapproved documents. But what if an interim amendment states a provision on a point nowhere even mentioned in the preceding cycle's IRS-preapproved documents? Without defeating reliance on the most recent IRS opinion letter, may a user change a provision the IRS never vetted?

"I don't yet know whether anything might call for even considering a change. But here's why understanding the rules matters. If a change would defeat reliance, I might narrow the scope of my review and spend less of my client's money and attention. Or if a change would not defeat reliance, I can, before I start work, ask my client how much or how little it wants me to review. And knowing the rules I might have better knowledge to form my advice about whether a change might be worthwhile.

"I know many plan sponsors never seek a lawyer's review of what a recordkeeper or other service provider has presented. But for those of us who are asked, the client and the lawyer together need to define what the lawyer is looking for, and, often more important, what not to consider. I understand that I alone am responsible for any advice to my client."