Excerpt: In general, plans must be updated for a change in the qualification requirements, or a change that is integral to a change in the qualification requirements, by the due date of the employer's tax return (including extensions) for the year in which the change is effective.... Regardless of the general rule ... , the timing of an amendment cannot result in a violation of the anti-cutback rules of Code § 411(d)(6). This means that, in some cases, the amendment must be adopted sooner than the deadlines stated above .... Unfortunately, there is no guidance from the IRS regarding the interaction of the changes made by the Final 415 Regulations and the anti cutback rules.  MORE >>