March 2, 2016
To keep their plans qualified, all employers with defined contribution (DC) plans that use pre-approved plan documents (i.e., master and prototype or volume submitter documents) must readopt those plans by April 30, 2016.
Many providers of pre-approved plans assist their customers by sending new adoption agreements that have been pre-completed and are ready to be signed. While it is convenient for employers to receive these signature-ready documents, they should carefully review the new agreements before signing them. Such a review should compare the new agreement to the old, and also should include a review of the current SPD and other relevant documents to ensure that all plan documentation is consistent. Adopting an agreement that contains mistakes, or that no longer reflects plan operations, is likely to result in document or operational errors that could be costly to correct in the future.
Working with plan attorneys, Sibson’s compliance experts are available to assist in the review of new agreements. If you are in the process of readopting a pre-approved DC plan and would like our help, please contact your Sibson consultant.
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