"The revised deadline [in Rev. Proc 2021-38] for interim amendments by pre-approved plans is consistent with contemporaneous new guidance for 403(b) plans (in Rev. Proc. 2021-37) ... The deadlines for pre-approved and individually designed plans still are not identical, however, because the two-year period for individually designed plans isn't triggered until a change appears on a Required Amendments List, which generally happens only after guidance for the item has been provided."  MORE >>