A new year has dawned, bringing into sharper relief that deadlines relevant to 403(b) documents come closer.
Updating Documents
March 31, 2020 is the deadline for 403(b) plans to update their plan documents for all current law.
Revenue Procedure (Rev. Proc.) 2019-39, which became effective Sept. 30, 2019, establishes a remedial amendment period for individually designed plans after March 31, 2020. The guidance sets forth a system of recurring remedial amendment periods for correcting form defects in individually designed and 403(b) pre-approved plans first occurring after the initial remedial amendment period ends on March 31, 2020, and provides a limited extension of the initial remedial amendment period for certain form defects.
Plan Amendment Deadlines for New Hardship Rules
The IRS released the annual required amendment list for individually designed qualified plans and 403(b) plans in Notice 2019-64. Sponsors of individually designed 401(k) and 403(b) plans have until Dec. 31, 2021, to adopt amendments to meet the requirements of the final hardship regulations.
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