|An IRS official informally has indicated an employer will have until the end of its remedial amendment period (including the extension for prototype and volume submitter plans) to adopt the RMD model amendment for the 2001 plan year. The benefit of this additional time period to adopt the model amendment is that a practitioner can have the employer adopt the model amendment as part of its GUST restatement instead of requiring the employer to execute a separate amendment. The SunGard Corbel prototype and volume submitter documents (Corbel, PPD and FDP) will incorporate the model amendment.
Note: In a previous web article, we reported that an employer does not need to adopt the model amendment prior to making distributions under the RMD rules. However, the employer would need to adopt the model amendment before its remedial amendment period expires and would need to apply it retroactively to the 2001 plan year.