May 27, 1992
TO: PENSION MEMBERS NO. 11-92
RE: IRS ALLOWS SIMPLIFIED METHOD OF AMENDING PROTOTYPE PLANS
__________________________________________________________
Attached is a copy of Revenue Procedure 92-41, which
provides a simplified method by which prototype sponsors that
received favorable opinion letters after January 1, 1990, may
amend their plans to take advantage of liberalized rules
contained in final regulations under sections 401(k) and 401(m)
of the Code and the new definition of compensation under section
1.415-2(d)(11)(i) of the regulations.
Amendments concerning the definition of compensation may be
accomplished without the necessity for application to the IRS
through adoption of model language set forth in the revenue
procedure. Individually drafted amendments relating to the
definition of compensation or the various issues under sections
401(k) and 401(m) that are listed in the revenue procedure must
be submitted to the IRS for review, but such applications will be
handled on an expedited basis and no user fee will be incurred.
We will keep you informed of further developments.
Kathy D. Ireland
Associate Counsel - Pension
Attachment