The 2022 Cumulative List will assist providers of Section 403(b) pre-approved plans applying to the IRS for opinion letters.
Reported by Rebecca Moore
The IRS has issued Notice 2022-8, laying out the 2022 Cumulative List of Changes in requirements for Section 403(b) pre-approved plans.
The 2022 Cumulative List will assist providers of Section 403(b) pre-approved plans applying to the IRS for opinion letters for the second remedial amendment cycle (Cycle 2) under the 403(b) pre-approved plan program. Cycle 2 began on July 1, 2020.
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The 2022 Cumulative List identifies changes in the requirements of Section 403(b) of the Internal Revenue Code (IRC) that will be taken into account by the IRS with respect to a plan document submitted to the IRS for Cycle 2 and that were not taken into account during the first remedial amendment cycle (Cycle 1). Section 403(b) plans may be submitted for approval during the Cycle 2 submission period, which begins May 2, 2022, and ends May 1, 2023.
Revenue Procedure (Rev. Proc.) 2021-37 set forth the agency’s procedures for issuing opinion letters regarding satisfaction in the form of 403(b) pre-approved plans with respect to the requirements for Cycle 2. It also set forth the rules for determining when Remedial Amendment Periods expire for 403(b) pre-approved plans.
In Rev. Proc. 2019-39, the IRS established a recurring remedial amendment period for 403(b) plans and extended the initial remedial amendment period beyond March 31, 2020, for certain form defects.
The IRS said Rev. Proc. 2021-37 modified the procedures for the 403(b) pre-approved plan program to be more similar to those applicable under the IRC Section 401(a) pre-approved plan program.
The 2022 Cumulative List includes, among other things:
