401(a) plan interim amendment deadlines updated


The IRS recently issued Rev. Proc. 2021-38, modifying the deadline for adopting interim amendments for Section 401(a) pre-approved plans.

For disqualifying provisions that are effective after Dec. 31, 2020, plan adopters must adopt interim amendments by the end of the second calendar year following the calendar year in which the change in qualification requirements is effective.

Disqualifying provisions effective on or before Dec. 31, 2020, will be deemed timely if an interim amendment is adopted by the end of the remedial amendment period described in Section 2.07 of Rev. Proc. 2016-37.



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