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

The Coronavirus Aid, Relief, and Economic SecurityAct (CARES Act) has extended several important deadlines for sponsors of 403(b) and defined benefit plans:

Initial remedial amendment period for 403(b) plans extended to June 30, 2020. 

The initial remedial amendments deadline for 403(b) plans has been extended by three months, from March 31, 2020, to June 30, 2020.  Plan sponsors now have additional time to restate or update their documents, including correcting any form defects in their plan documents retroactive to January 1, 2010 per Revenue Procedure 2019-39.

Minimum funding contribution delay for single-employer defined benefit plans until January 1, 2010.

Minimum funding contributions may now be delayed by single-employer defined benefit plan sponsors until January 1, 2021.  Employers will still need to pay interest on the delayed contributions according to the plan’s effective rate.

Extensions for pre-approved defined benefit plans.

Under the second six-year remedial amendment cycle, the previous deadline for the adoption of a pre-approved defined benefit plan and submission of a determination letter application was April 30, 2020.  That deadline has been extended to July 31, 2020.  The end of the second six-year remedial amendment cycle has been extended to July 31, 2020 as well.

The third six-year remedial amendment cycle now begins August 1, 2020 with an end-date of January 31, 2025.  The opinion letter submission period also begins August 1, 2020 and ends on July 31, 2021.

In the near future, the IRS is expected to issue guidance on second and third six-year remedial amendment cycle extensions.

We help organizations set up the benefits plans that are right for their members, put processes in place to ensure regulatory compliance, and keep those benefit plans updated based on changes in laws and regulations. To learn more about the services we offer, call 678-439-6236 today.

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Hall Benefits Law, LLC

HBL offers employers comprehensive legal guidance on benefits in mergers and acquisitions, Employee Stock Ownership Plans (ESOPs), executive compensation, health and welfare benefits, healthcare reform, and retirement plans. We counsel a wide spectrum of clients including small, mid-sized, and large companies, 401(k) investment advisors, health insurance brokers, accountants, attorneys, and HR consultants, just to name a few. HBL is passionate about advising clients, and we are dedicated to our mission: to provide comprehensive, personalized, and practical ERISA and benefits legal solutions that exceed client expectations.

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