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Attention Sponsors of 403(b) Plans: You May Need to Take Action by June 30

Tax-Exempt Organizations Alert Michael C. Wieber

Piggy bank with sign 403b on a side.

Some organizations may not have yet had their 403(b) plans reviewed to ensure that plan terms reflect tax qualification provisions. According to the most recent guidance from the IRS, these changes should be incorporated in plans by June 30, 2020.

The good news is that these are simply provisions that reflect the current status of the law. There are no decisions required by you at this point.

Importantly, if your plan uses a pre-approved document (generally referred to as a "prototype" or "volume submitter" plan), your document provider typically would have taken all necessary action to incorporate required provisions on your behalf already.

If you are not certain or have not discussed this deadline with your document provider, please provide us with a copy of your plan, and we can do a quick review to ensure compliance. If your plan needs amendments, we can prepare them in time for adoption by the end of the month.

Importantly, note that changes to documents for hardship withdrawals (under early 2018 tax legislation), the SECURE Act and the CARES Act are not due until at least December 31, 2021. We are only referring to changes that predate those new laws.

Please don't hesitate to contact us if we can be of assistance:

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