"In an effort to further enhance the effectiveness of the current pre-approved plan programs, the ARA recommends: [1] The establishment of a single, streamlined revenue procedure that covers both 401(a) qualified plans and 403(b) plans ... eliminating distinctions (substantive, procedural and terminology) currently associated with 'M&P' and 'volume submitter' plans. [2] Specific enhancements to improve and expand the availability of pre-approved plans in light of the changes to the determination letter program for individually designed plans. [3] An initial restatement period of three years for employers adopting pre-approved 403(b) plans. [4] The addition of 457(b) plans to the pre-approved plan program."

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