The IRS today released an advance version of Notice 2019-64 providing the “2019 required amendments list.”
As explained by Notice 2019-64 [PDF 57 KB], beginning with the 2019 list, all required amendments lists will apply to both individually designed plans qualified under section 401(a) and individually designed plans that satisfy the requirements of section 403(b).
Notice 2019-64 further explains that in general:
Therefore, for these purposes, December 31, 2021, would be the last day of the remedial amendment period for a qualified individually designed plan or a form defect in a section 403(b) individually designed plan; and also the plan amendment deadline for a disqualifying provision arising as a result of a change in qualification requirements that appears on the 2019 required amendment list and for a form defect arising as a result of a change in section 403(b) requirements that appears on the 2019 required amendment list.
The IRS notice states that later dates may apply to a governmental plan (under section 414(d)).
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