NONBANK TRUSTEE MAY ACT AS SPONSORING ORGANIZATION OF MASTER PENSION PLANS

Rev. Proc. 84-83

SECTION 1. PURPOSE

This revenue procedure modifies section 4.06 of Rev. Proc. 84-23, 1984-12 I.R.B. 14, to permit a nonbank trustee to be a sponsoring organization of a master or prototype plan.

SEC. 2. BACKGROUND AND GENERAL INFORMATION

01 Rev. Proc. 83-36, 1983-1 C.B. 763, sets forth the general procedures of the Internal Revenue Service relating to the issuance of rulings determination letters, and opinion letters on employee plan and exempt organization matters.

02 Rev. Proc. 84-23 sets forth the general procedures relating to the issuance of opinion letters by the National Office as to the acceptability of the form of master and prototype pension, annuity, and profit-sharing plans involving sections 401 and 403(a) of the Internal Revenue code, and the status for exemption of related trusts or custodial accounts under section 501(a).

03 Section 8.01 of Rev. Proc. 84-23 provides that opinion letters will be issued only to sponsoring organization.

04 Section 1.401-12(n) of the Income Tax Regulations provides rules relating to nonbank trustees, including the procedural administrative rules for obtaining approval from the Service to act as a nonbank trustee of trusts forming part of employee plans.

SEC. 3. MODIFICATION OF REV. PROC. 84-23

Section 4.06 of Rev. Proc. 84-23 is hereby modified to provide that a sponsoring organization includes a person that has been approved by the Service, in accordance with section 1.401-12(n) of the regulations, to act as a nonbank trustee.

SEC. 4. EFFECT ON OTHER DOCUMENTS

Section 4.06 of Rev. Proc. 84-23 is modified as described above.

SEC. 5. EFFECTIVE DATE

This revenue procedure is effective for all applications for an opinion letter submitted on or after June 17, 1984.