Chart of Defined Contribution Plan Amendments
From the TRA '86 Document to the GUST Document
June 22, 2007 |
When taking over plan, what amendments should be in the file?
|
Amendment |
Usage |
Deadline |
MHCO Prototype* |
| |
| Restatement of TRA '86 Document |
Incorporate changes from TRA '86 |
Last day of plan year beginning in 1994 |
Last day of Plan Year beginning in 1994 |
| UCA '92; 401(a) (31) |
Direct rollover and mandatory withholding rules created and required to be added to plan |
Last day of plan year beginning in 1994 |
Included in MHCO TRA '86 document |
| OBRA '93: 401(a) (17) |
Compensation Cap 401(a) (17) limited to $150,000 and subejct to COLA, required to be added to the plan |
Last day of plan year beginning in 1994 |
Document sponsor amendment snapped onto the back of the MHC TRA '86 Basic Plan Document (BPD) |
| Waiver of 30 day period for 402(f) Notice, Rev. Proc. 93-47 |
Permits safe harbored profit sharing plans to waive the 30 day wait on distributions if the plan is not subject to QJSA |
Optional Amendment |
Document sponsor amendment snapped onto the back of the MHCO TRA '86 BPD |
| For other statutory changes between 1994 and 2000, plan had to be operated in compliance with the law change, but did not have to be amended for the law until the GUST document adoption deadline. Terminating plans during this period had to be amended for all the relevant law changes. |
Defined Benefit Plan Amendment |
| GATT DB Plans |
New DB plans established after Dev. 7, 1994 |
DB Plans existing before Dec. 7, 1994, the later of tax filing deadline for employer's tax year which includes the first day of the new plan year, or the GUST RAP deadline |
DB Plans existing before Dec. 7, 1994, the later of :
-tax filing deadline for the employer's tax year which includes the first day of the new plan year, or
-the GUST RAP deadline |
| |
| *Note: There was no MHCO Volume Submitter plan prior to GUST, so there is no corresponding VS column. |
| Chart of Amendments from GUST to PPA |
To learn more, call 973-492-1880 or e-mail info@mhco.com.
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