IRS Extends Deadlines for 403(b) Plans and Pre-Approved Defined Benefit Plans

by: Smith and Howard

April 9, 2020

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As a result of the COVID-19 pandemic, the Internal Revenue Service (IRS) has announced that plan sponsors now have three additional months to amend any of their 403(b) plans that do not currently meet certain requirements. The initial remedial amendment period for 403(b) retirement plans has been extended from March 31, 2020 to June 30, 2020. Tax-exempt organizations and governmental employers who sponsor these plans now have until June 30 to amend an individually designed plan or adopt a pre-approved one.

Individually Designed Plans

403(b) plan sponsors with individually designed plan documents that were intended to comply with the applicable code but failed to do so because of defects to the form of the document will now have until June 30, 2020 to retroactively correct them. These corrections can be applied retroactively as far back as January 1, 2010 or the plan’s effective date, only if the plan sponsor meets the June 30, 2020 deadline. They will have to either amend the existing plan or adopt a pre-approved plan document.

Pre-Approved Defined Benefit Plans

The deadline to adopt a pre-approved defined benefit plan has extended from April 30, 2020 to July 31, 2020. Plan sponsors can use this additional time to initiate a restatement process and complete the required administrative tasks that the process requires.

Some retroactive amendments can be complicated. To ensure you meet the correct deadlines, contact your Smith and Howard advisor with your questions or complete the contact form below.

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