Attention Plan Document Sponsors: Restatement Submission Deadline Is Approaching

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If your organization sponsors plan documents for your qualified retirement plan (QRP) business, you likely know that the deadline to submit your next application to the IRS is quickly approaching. With the IRS’ six-year cycle system for required document updates, the third restatement cycle (known as “Cycle Three”) doesn’t end until 2022. But with the submission deadline coming soon, document drafters like Ascensus have already started preparations and document drafting to ensure that document sponsors can timely submit on-cycle applications to the IRS. Read on for more information about steps you may need to take immediately.

Cycle Three Submissions Are Due December 31

The end of the on-cycle submission period for document providers to submit required documents and fees to the IRS on behalf of their document sponsors for Cycle Three documents is December 31, 2018. (The original deadline was October 2018, but Revenue Procedure (Rev. Proc.) 2018-42, released in August, extended the deadline to December 31, 2018.)

If you currently sponsor the Ascensus document for your QRP customers (or you would like to sponsor the Ascensus pre-approved document for Cycle Three), we must receive your completed request and IRS fees by November 30, 2018, so that we can timely submit your on-cycle application to the IRS for the new Cycle Three documents.

Ascensus will work with the IRS to complete the submission process for your document sponsorship. Based on the submission deadline extensions the IRS has already granted, it remains somewhat unclear just when the IRS will complete its review of the Cycle Three pre-approved documents and issue opinion letters. Clarification is expected from the IRS in the near future.

Remember, We Can Sponsor on Your Behalf

Ascensus can assume responsibility for your QRP documents by becoming the prototype document sponsor for your employer plans through its Employer Direct Document Service (EDDS). As the prototype document sponsor, Ascensus will take care of the amendment, restatement, and plan establishment process for all of your current and future employer plan clients. The EDDS is an affordable total document solution that will relieve the burden associated with document sponsorship—particularly during IRS amendment and restatement events. Please let us know if you would like additional information about the exciting benefits of this service.

Changes to IRS Program Lead to New Document Options

In June 2017, the IRS released Rev. Proc. 2017-41, which provides the deadline to submit new opinion letter applications during Cycle Three (this deadline was amended by Rev. Proc. 2018-42). Rev. Proc. 2017-41 also describes significant changes to the pre-approved QRP document program—including a newly combined prototype and volume submitter program. The combined document program will provide greater flexibility in QRP document design, permit customization of nonstandardized documents, and result in a single opinion letter program.

The new restatement guidance allows Ascensus to streamline the offerings under our prototype document program. We will offer both a standardized and a nonstandardized version for our pre-approved QRP adoption agreements.

Customizations to Ascensus’ pre-approved documents will be available through our proprietary QRP document generation and management system, the Plan Adoption System (PAS).

The PAS has the capability to produce plan documents that contain only the provisions applicable to each of your employer plans and create dynamic summary plan descriptions (SPDs) that are systematically generated from the information in the adoption agreement, providing a customized SPD for your adopting employers and their employees. It also gives you access to a wide array of features, such as automatic document updates for legislation, amendment integration, automation capabilities, and document version history.

Ascensus Is Here to Help

Don’t hesitate to contact us at 800-346-3860 or with any questions you have about the new pre-approved document program, your documents, and the services Ascensus provides. We are here to help.

 Plan Adoption System™ is a trademark of Ascensus, LLC.