Advisory Committee on Tax Exempt and Government Entities (ACT ...

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PROTECTING PLAN BENEFITS:IMPROVING GOVERNMENTAL DEFINED CONTRIBUTION PLAN COMPLIANCEthe United States where it is accessible during every business day, and (2) either has atleast 30 clients that have their principal place of business within the jurisdiction of notmore than two regions of the IRS and are expected to adopt the sponsor’s regionalprototype plan, or has at least three clients that are expected to adopt a “mass submitterregional prototype plan.” 39The regional prototype plan program and the M&P plan program operated separately,each being amended a number of times thereafter as procedural requirements changedin accordance with the law, until the two were finally unified under a single Master andPrototype plan program in 2000. Stating that it was no longer practical to maintainseparate programs, the IRS issued Rev. Proc. 2000-20, creating one set ofrequirements and procedures for all Master and Prototype plan sponsors and expandingthe availability of options previously available to only one program to make themuniversally available under the Unified Program.Since 2000, there have been minor amendments to the Unified Program, most notableof which was in 2005, when the IRS issued Rev. Proc. 2005-16, attempting to simplifyand combine the otherwise separate programs for Pre-approved plans.Rev. Proc. 2005-16 sets forth the IRS’ current procedures for issuing opinion andadvisory letters regarding the qualification of pre-approved plans under Sections 401(a)and 403(a) of the Code. It delineates the requirements and responsibilities ofSponsoring Organizations and Adopting Employers in connection with theestablishment, qualification and operation of pre-approved plans.The Rev. Proc. further provides that a Sponsoring Organization’s failure to comply withany requirement delineated, including the notice and recordkeeping requirements, mayresult in the loss of the ability to maintain a Master and Prototype plans or therevocation of an existing opinion letter.39Id. at §4.02ADVISORY COMMITTEE ON TAX EXEMPT AND GOVERNMENT ENTITIES (ACT) June 11, 2008 44
PROTECTING PLAN BENEFITS:IMPROVING GOVERNMENTAL DEFINED CONTRIBUTION PLAN COMPLIANCEAppendix FIRS <strong>Advisory</strong> <strong>Committee</strong> seeks input on Public Sector Plan RecommendationsProvided by: Julian ReganThe IRS <strong>Advisory</strong> <strong>Committee</strong> on Tax-Exempt and Government Entities (ACT) isreaching out to industry leaders including NADGCA to ensure public sector definedcontribution plan recommendations the committee is developing incorporate expertisefrom across the government plan community. NAGDCA members who have not doneso already may send comments to the ACT at one of the email addresses identifiedbelow by April 11, 2008.The ACT serves as an advisory group to the Commissioner, Tax-Exempt andGovernment Entities Division of the IRS and includes members from the employeeretirement plan, exempt organization and government entities communities.ACT recommendations are aimed at facilitating improved compliance for public sectordefined contribution (DC) plans. They will be finalized in late April for presentation to theIRS at a public meeting in June.The recommendations will likely encompass the following topics:• Potential establishment of a prototype system for public sector 401(a) DC plans.• Educational tools and initiatives the IRS might undertake to further facilitatecompliance across all categories of DC plans (e.g. 401(k), 401(a), 457, 403(b)).• General discussion of public sector compliance challenges, gaps and solutions.As many NAGDCA members know, a prototype system, such as the system currentlyavailable to corporate 401(k) plans, provides a standardized form of agreement andmay facilitate a lower cost of adoption as well as a reduced need for employer-initiatedamendments as tax laws change. In addition to addressing compliance challenges,such a system may encourage more employers to adopt plans, particularly amongsmaller entities. The ACT recommendations will weigh these potential benefits, alongwith input from stakeholders and the implications to the IRS of administering such asystem.Beyond exploring the concept of a prototype system, the ACT will recommend costeffectiveinitiatives the IRS might undertake to serve the needs of the public sector plancommunity across all categories of plans. Such initiatives may include tools to assistemployers and service providers in understanding and executing against statutoryrequirements. It should be noted that the IRS is already taking action in these areas.The ACT recommendations are intended to complement these efforts.The ACT first contacted NAGDCA on this project in the spring of 2007 and NAGDCAimmediately assisted by posting a survey to its web site. Beyond obtaining input fromADVISORY COMMITTEE ON TAX EXEMPT AND GOVERNMENT ENTITIES (ACT) June 11, 2008 45
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