With the passage of the Coronavirus, Aid, Relief, and Economic Security (CARES) Act on March 27, 2020, the IRS provided plan adoption and amendment relief to plan sponsors. Below are updated plan adoption and amendment relief timing affecting plan sponsors.

403(b) Plans

The IRS extended the last day for 403(b) plan sponsors to update their plan documents. Plan sponsors originally had until March 31, 2020 to restate or amend their pre-approved prototype and individually designed plan documents. They now have until June 30, 2020 to update these documents.

Pre-Approved Defined Benefit Plans

The IRS also extended the last day to adopt a pre-approved defined benefit plan, such as a cash balance plan or traditional pension plan. Originally, plan sponsors were required to adopt such a plan by April 30, 2020. The revised deadline to adopt a pre-approved defined benefit plan is now July 31, 2020. Plan sponsors adopting by that date will be considered to have timely adopted within the second six-year remedial amendment cycle.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.