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Are Individually Designed Retirement Plans an Endangered Species?
Vorys, Sater, Seymour and Pease LLP
Jan. 3, 2017 "As a result of the IRS' changes to its determination letter program, [plan sponsors should]: [1] Ensure that an annual review is performed for all retirement plans to confirm compliance with the IRS' Required Amendment List and Operational Compliance List. Document the annual review in the plan administrator minutes; amend the plans as required, and conduct operational audits to document your diligence.... [2] Carefully scrutinize all proposed amendments to the plan for potential issues. You will no longer be able to clean up problematic language during the determination letter process.... [3] Consider whether a pre-approved plan can satisfy the plan's design and legal requirements." MORE >> |
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