403(b) Restatement Reminder

March 17, 2020

403(b) plan sponsors have until March 31, 2020, to restate their plan document to retroactively correct defects back to the first day of the plan’s remedial amendment period. As background, 403(b) plans were required by law to establish written plan documents by January 1, 2009. However, the IRS didn’t establish the required plan language and terms until 2017. In IRS Revenue Procedure 2017-18, the IRS gave plan sponsors until March 31, 2020, to restate their plan to include the required plan provisions. Employers sponsoring 403(b) plans should work with their advisor to have their plan document restated if they have not already done so.