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PPA Restatement Cycle November 7, 2012 Presented By: Aimee Nash Holly Roussel-Godfrey.

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Presentation on theme: "PPA Restatement Cycle November 7, 2012 Presented By: Aimee Nash Holly Roussel-Godfrey."— Presentation transcript:

1 PPA Restatement Cycle November 7, 2012 Presented By: Aimee Nash Holly Roussel-Godfrey

2 Agenda  A few Basics About Restatement Cycles and Pre- Approved Plans  What's New for the PPA Cycle?  Product Offerings for PPA Cycle – Doc types  Do I Need a Letter in My Own Name?  Product Offerings for PPA Cycle – software features/Demos  Batch restatements  E-signature/portal/workflow  Other upcoming enhancements

3 Restatement Cycle Basics

4 Restatement Cycle  All pre-approved qualified defined contribution plans are on the same 6 year restatement cycle  Pre-approved DC plans last had to restate for EGTRRA by April 30, 2010  DB and 403(b) plans are on a different cycle  Pre-approved DB plans must have restated for EGTRRA by April 30, 2012  403(b) plans cycles - yet to be determined

5 Timeframes submitted draft documents to IRS April 2, 2012  Content of docs is determined by 2010 LRMs 2.IRS reviews documents – expected completion 2014? 3.Deadline to adopt PPA docs - early 2016?

6 What's New for the PPA Cycle (IRS Requirements per Rev Proc 2011-49)

7 Summary of Changes  Differences between vol subs and prototypes narrowing  Interim amendment certification requirement  Not much else

8 Prototypes vs. Vol Subs PrototypeVolume Submitter Document formatAdoption agreement and basic plan document All-in-one document or adoption agreement ("prototype") format Modifications to pre- approved language Plan becomes individually designed Most changes are 'minor modifications' HardshipSafe harbor onlySafe harbor or non-safe harbor permitted Participant waiver/ Irrevocable opt-out Not permittedPermitted Cross-testing – each participant in his own group EGTRRA: number of groups limited by number of NHCES PPA: works same as volume submitters No limit on number of groups Multiple Employer PlanEGTRRA: not permitted PPA: permitted Permitted

9 Interim Amend Certification  New requirement for PPA (Rev Proc 2011-49)  Required now for applications for letter in own name  This certification will be required of all customers – even if no opinion/advisory letter

10 Interim Amend Certification

11 PPA Documents

12 PPA Cycle Documents Offered  Prototype - nonstandardized plans  401(k)/Profit Sharing  401(k)/Profit Sharing Answers Only  Money Purchase  Target  Prototype - standardized plans  401(k)/Profit Sharing  401(k)/Profit Sharing Answers Only  Money Purchase

13 PPA Cycle Documents Offered  Volume Submitter plans  401(k)/Profit Sharing AA format  401(k)/Profit Sharing AA format Answers Only  Profit Sharing Governmental Plan AA format (no 401(k) provision)*  Money Purchase Governmental Plan AA format*  401(k) IDP format  Profit Sharing IDP format  Money Purchase IDP format

14 Governmental Plans  If you have individually designed governmental plans coming to end of 5- year cycle, use 8905 to bridge to PPA  Wolters Kluwer/ does not have mass submitter status – must use our advisory letter for governmental volume submitter documents

15 Prototype or Vol Sub?  We generally recommend Volume Submitter in prototype format.  Checklist nearly identical to NS proto (only differences are those required by the IRS – Proto NS is generally not "simpler")  Differences weigh in favor of Vol Sub (minor mods and non-safe harbor hardship option)  Prototype format easier to read

16 New AA Document Format – applies to all plans w/ AA  Each question now has a heading.  Sub-questions are now indented.  More descriptive words instead of question numbers.  Instead of:  "The exclusion listed in B.1a for union employees applies for the following purposes:"  New style:  "The union employees exclusion listed above applies for the following purposes:"

17 New AA Document Format Cont.  Technical information removed from the question.  Instead of:  "If B.4a is selected, describe other excluded Employees from definition of Eligible Employee and indicate for what purposes (e.g., Elective Deferrals, Matching, etc.) the Employees are excluded: ______"  new style:  "Other Employees: ______"  "NOTE: If selected, describe other excluded Employees from definition of Eligible Employee and indicate for what purposes (e.g., Elective Deferrals, Matching, etc.) the Employees are excluded."

18 Document Language Walk Through

19 Caveats  Document is not yet approved  We are showing a *DRAFT* document

20 Document Highlights - 1  No amendment to update company information  "Testing Compensation" now called "Statutory Compensation" to help clarify not used for ADP/ACP but 415, HCE/Key and top heavy determinations only  More "other" options throughout the document  Software will allow you to apply the same eligibility rules to all contributions

21 Document Highlights - 2  New section for safe harbor and elective deferrals (apart from profit sharing / match)  Safe harbor match eligibility options now same as non-electives  Automatic enrollment per admin policy  Allocation service language clarified  Amount of Profit sharing now an option  New "other" profit sharing formula

22 Document Highlights - 3  Paid time off option (rev procs 2009-31/32)  Most QNEC language removed to BPD – allocations at plan admin discretion  Forfeitures can be set in doc or remain as any permissible method  Domestic partner language added (optional)  Ability to add custom policy when no beneficiary exists  More flexible hardship for certain accounts

23 Document Highlights - 4  New in-service option age and service  Special trustee for purposes of determining and collecting contributions under the Plan  Trust administrative modification options

24 Answers Only Option Example 1.Union Employees a.[ X ] Any Employee who is included in a unit of Employees covered by a collective bargaining agreement, if retirement benefits were the subject of good faith bargaining, and if the collective bargaining agreement does not provide for participation in this Plan. b.The union employees exclusion listed above applies for the following purposes: i.[ ] Elective Deferrals and Voluntary Contributions. ii.[ X ] Matching Contributions. iii.[ X ] Profit Sharing Contributions. Text crossed out above will not appear. If 1.a. was not selected, entire question would not appear.

25 Answers Only Option Details  BPD must include Appendix A showing an entire Adoption Agreement with all applicable text, notes, etc.  Answers only AA must include the following statement:  "By signing this adoption agreement, the adopting employer acknowledges having reviewed the Appendix A and certifies that all choices reflected in this adoption agreement have been taken from such appendix."

26 Pre-release program  Current customers can access draft PPA document from website  Prospective customers – contact  Participants can review draft copies of the VS prototype format and suggest improvements and possible new features.

27 Should I Get a Letter in My Own Name?

28 No requirement to get a letter in your own name  IRS does not require this; recognize "middlemen" that use a vendor's opinion/advisory letter  Some document vendors require letter in own name to use their documents  allows customers to use its letters and/or apply for a letter in customer's name

29 Do I need to be on a list with a vendor?  If you had a letter in your own name for the EGTRRA cycle, you should consider getting a letter in your name for PPA  If you had no letter last cycle, you certainly do not need a letter for PPA – there's no "list" applicable  If you apply for a letter with one vendor – you can change your mind  for details

30 Advantages of having letter in your own name  You can use your company name on the document (instead of Wolters Kluwer or leaving blank)  You can amend plans that use your letter on behalf of the plan sponsor (you can choose your own default amendment or apply different defaults to different plans)

31 Dis-advantages of having letter in your own name  You must amend plans using your letter for default provisions ( signed default amendment will not apply)

32 How Do I Apply For a Letter in My Firm's Name?  Items needed (email  Order Form  2848  Certification regarding interim amendments  Payment ($300 per doc type)  Applications with another vendor can be transferred if letters have not yet been issued  No firm due date for these applications – prior to 2014 is best

33 Product Offerings for PPA Cycle Software Features

34 Restatement Process  "Click of a button" restatement  Answers from prior document will map  Any new questions can be defaulted  Conversions can be batched into groups  If no changes during restatement, no data entry required to restate

35 Current Software Features  Batch amendments/Annual Notice  Portal product  integration with batch amendments/annual notices  e-signature  Live demonstration will follow power point presentation

36 Other Anticipated Software Features  Enhancements to edit checks and data entry of checklists  Customizable documents, SPDs and forms  Add logo (to forms/spds)  Choose margins, spacing between paragraphs, etc.  Add custom language  Reporting enhancements  Workflow / practice management  Multiple Employer plan software solution  Fullfillment options for restatements, amendments and annual notice – Wolters Kluwer prints and mails

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