As a result of COVID-19, on March 27 the IRS made two important announcements for certain retirement plan sponsors. First, the IRS extended the last day of the initial remedial amendment period for 403(b) plans from March 31, 2020 to June 30, 2020. As a result, plan sponsors now have until June 30, 2020 to update their pre-approved and individually-designed 403(b) plan documents for law changes that have occurred over approximately the past ten years. I have been busy assisting several 403(b) plan sponsors with this process, so please let me know if you or any of your contacts requires assistance in this regard.
Second, the IRS extended the following deadlines to July 31, 2020: (1) the April 30, 2020 deadline for employers to adopt a pre-approved defined benefit plan and to submit a determination letter application (if eligible) under the second six-year remedial amendment cycle; and (2) the April 30, 2020 end of the second six-year remedial amendment cycle for pre-approved defined benefit plans. The IRS also stated that employers that adopt, by July 31, 2020, a pre-approved defined benefit plan document that was approved based on the 2012 Cumulative List will be considered to have timely adopted the plan document within the second six-year remedial amendment cycle.