Pension Protection Act Blog

From the Cincinnati Benefits Conference today comes information about the amendment for the Final 415 Regulations. The IRS will not be issuing a model or sample amendment, so plan sponsors should plan on adopting a good faith amendment to incorporate the changes made by these regulations into their plan documents.

The deadline for adopting the amendment is the tax filing deadline for the 2008 plan year. For calendar year plans, this means that the deadline is March 15, 2009, or September 15, 2009.

The Final 415 Regulations were released on April 5, 2007, and the IRS released a special 2-page edition of Employee Plan News in April of 2007 containing a summary of the changes made by the Final 415 Regulations.

For pension geeks, the IRS released the revised version of the Defined Benefit List of Required Modifications (LRM). Contained within this LRM is around 20 pages on plan language to incorporate the Final 415 Regs into prototype plan documents. It is a must read for anyone thinking of drafting a good faith Final 415 Reg amendment.

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