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IRS delays Section 403(b) written plan document requirement

403(b) plan sponsors who haven’t yet adopted a written plan document that complies with the IRS final 403(b) regs–which had been required by December 31, 2008– can breathe a sigh of relief. The IRS has issued Notice 2009-3 which extends the deadline for adopting a written plan document that complies with the final regs until December 31, 2009. The plan document must be effective as of January 1, 2009, and the plan sponsor must operate the plan in compliance with section 403(b) and the final regs during 2009. The employer must also make its “best efforts” before 2010 to retroactively correct any operational failures that occur during 2009. The IRS also announced its intent to assist plan sponsors by allowing prototype 403(b) plans, and by initiating a determination letter program for individually designed 403(b) plans. For a copy of IRS Notice 2009-3, click here.

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