DB Plans in Second Six-Year Cycle Have Longer to Adopt Pre-Approved Plans

The IRS extended the period to adopt an approved plan document to April 30, 2020, from January 31, 2019.  

The Internal Revenue Service (IRS) intends to issue opinion and advisory letters for pre-approved master and prototype (M&P) and volume submitter (VS) defined benefit (DB) plans that were restated for changes in plan qualification requirements per the 2012 Cumulative List, and that were filed with the IRS during the submission period for the second six-year remedial amendment cycle on March 30, 2018, or, in some cases, as soon as possible thereafter. 

An employer using these pre-approved plan documents to restate a plan for the plan qualification requirements included on the 2012 Cumulative List will be required to adopt the plan document by April 30, 2020—an extension of the previous January 31, 2019 deadline.  

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An adopting employer whose DB plan is eligible for the six-year remedial amendment cycle system under section 19 of Rev. Proc. 2016-37, and who adopts, by April 30, 2020, an M&P or VS defined benefit plan that was approved based on the 2012 Cumulative List, will be considered to have adopted the plan within the second six-year remedial amendment cycle. 

Section 16.01 of Rev. Proc. 2016-37 provides that the third six-year remedial amendment cycle for DB pre-approved plans begins on February 1, 2019. The IRS says it will announce in future guidance a later starting date for this third six-year remedial amendment cycle.

Investors Across Five Decades Feel Confident

However, their top three financial fears include health challenges, job loss and market volatility

American investors across five decades, between 30 and 79, are optimistic about their finances, even though they have faced challenges, Ameriprise Financial learned in a survey of individuals with at least $100,000 in household investable assets. Ninety-five percent said they feel confident about their financial future.

Nonetheless, 80% said they have faced setbacks that have impacted their financial journey, and many are concerned about additional obstacles that lie ahead.

The survey found that the top financial setback for those in their 30s and 40s is a job loss or career issue. Older respondents point to market loss and health challenges. While 62% say they have recovered from these setbacks, they are still afraid of potential bumps down the road.

“Investors at various ages and stages of life who are taking action to manage their money feel financially confident despite the obstacles they’ve faced,” says Marcy Keckler, vice president of financial advice strategy at Ameriprise Financial. “While everyone has unique goals, needs and challenges that change throughout their lifetime, an important factor remains the same: planning for both today and tomorrow reinforces their sense of security and their long-term financial success.”

The survey also found that 78% say they have more than enough money to cover essential expenses, and 78% believe they are better off financially than others their age. When asked what financial success means to them, the most common response is having a sense of security, followed by being able to provide for their family.

Although respondents have household investable assets of $100,000 or more, 34% have a household income of less than $100,000, which indicates how proactive they have been about saving and investing, Ameriprise says. Seventy-five percent of respondents say they are diversifying investments, 61% are paying down debt, and 66% are participating in their workplace retirement plan. In fact, 55% started participating in the plan in their 20s.

Asked what personal milestone has had the biggest financial impact for them within the past five years, those in their 30s say buying a home. For those in their 40s, it’s starting or changing jobs; for those in their 50’s, it’s supporting their children’s accomplishments; and for those in their 60s and 70s, it’s retirement.

Seventeen percent said they are in the early stage of their financial journey. Forty-eight percent said they are in the middle phase, and 35%, the later period. In the early stage, investors are looking to balance accumulating assets with managing debt. In the middle stage, optimizing savings and investments is a priority, while in the later financial stage, it is determining draw-down strategies and adjusting investments to make their money last.

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Twenty-three percent of those with a retirement account said they have either borrowed from it or taken out an early withdrawal. Ninety-three percent who have taken out a loan have paid it back. Only 28% have long-term disability insurance, and 25% have long-term care insurance.

Artemis Strategy Group conducted the online survey of 3,019 adults for Ameriprise last December.

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