IRS Updates Operational Compliance List for 2020

July 21, 2020

On July 8, 2020, the IRS updated their operational compliance list (OC List) to recognize the final regulations relating to hardship distributions and to reflect all the changes made by the Setting Every Community Up for Retirement Enhancement (SECURE) Act. As background, the OC List is provided by the IRS to help plan sponsors and practitioners achieve operational compliance by identifying changes in qualification requirements effective during a calendar year.

The updated list incorporated the most recent changes to the hardship distribution rules and describes the necessary plan amendments relating to hardship distributions. The list also highlights the plan amendments necessary to reflect the changes that were brought on by the SECURE Act. (We discussed the SECURE Act at length in the January 7, 2020 edition of Compliance Corner.)

The IRS periodically updates the OC List to reflect new legislation and guidance. As such, it is a useful tool for plan sponsors. However, the list is not intended to be a comprehensive list of every item of IRS legislation or guidance. Plan sponsors should work with their advisers to ensure their continued compliance with the retirement plan regulations.

Operational Compliance List »