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The 'Missive Gap': Employers to Cope Without Updated Plan IRS Determination Letters (PDF)
Jackson Lewis P.C. Link to more items from this source
[Guidance Overview]
Oct. 25, 2016

"[T]he new normal for [individually designed plans (IDPs)] will likely be extensive periods of plan life between initial plan adoption and plan termination in which plan sponsors will need to rely upon their judgment and that of their counsel and other plan advisors with respect to their compliance with new IRS plan document maintenance requirements. Some of the newly announced features provide employers some comfort, but the reality is that the maintenance of an IDP plan document in the future will likely entail inherently more employer risk and exposure than it has in the past."

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