Volume Submitter Defined Benefit Plan PPA Restatement
We are happy to announce that Document Agility, Inc. has received favorable approval for its Defined Benefit Volume Submitter Plan as restated for The Pension Protection Act of 2006 (PPA), along with approval letters for each of its word-for-word adopters who timely filed their applications before October 30, 2015.
According to the IRS, those who filed after the application deadline will receive their letter later this year, sometime in late-September/early-October. Although the restatement period is shortened, retroactive reliance remains applicable for such letters.
If you are a word-for-word adopter of this plan, please look for a direct email regarding the status and a copy of your letter issued March 30, 2018. If you will be using Document Agility’s opinion letter, look for it to be posted to the AccuDraft.com website in the next few days.
Conversion of EGTRRA Answers to PPA Answers
For DB plans currently on DocsEngine system, answer sets for EGTRRA DB plans can be used as a base for creating the corresponding PPA DB plans with a large percentage of information carried over, thereby limiting the amount of new input necessary. However, some data, such as new or substantially changed provisions and effective dates will require data entry.
For DB plans currently in the AccuDraft Pro desktop product, answer files for EGTRRA DB plans can also be used as a base for creating the corresponding PPA DB plans, with the same percentage of information carried over. Again, new or substantially changed provisions and effective dates will require data entry.
In all cases, we highly recommend that PPA documents be carefully verified before providing them to your clients.
Timing of New Documents
Due to the flexibility and complexity of the restated document, testing of the automated program is still ongoing. At this time, we estimate that the document and its corresponding summary plan description will be available by June 1, 2018.
Adopting employers restating for PPA must adopt the pre-approved plan by April 30, 2020. The IRS will start accepting applications for individual determination letters (see Revenue Procedure 2018-04 for guidance and applicability) starting May 1, 2018. The IRS has not yet issued guidance for the next six-year remedial amendment cycle for pre-approved defined benefit plans (originally set for February 1, 2019).
If you have any questions, please do not hesitate to contact us.