The IRS recently issued an updated Listing of Required Modifications and Information Package (known as the “LRMs”) for 403(b) plans. These LRMs contain quite a few changes, from simple clarifications and explanatory notes, to more substantive revisions to plan language reflecting changes arising from the PATH, SECURE and CARES Acts. While the LRMs are intended for 403(b) plans that use “pre-approved” plan documents, sponsors of individually designed 403(b) plans also frequently look to the LRMs for insight into what the IRS views as acceptable plan language. We point out some of the more noteworthy changes in the latest LRMs below.
