Attorney Submits Comments on Employee Plans Determination Letter Program

Dear Sir/Madam:

[1] In response to your request for comment related to Announcement 2003-32, the proposal related to a five year staggered term sounds more efficient than the present system. I would not support the annual update of the plans under a staggered review policy in that it would create additional costs to the operation of the plan to maintain these annual updates. If annual updates were approved I would highly recommend that model amendments be issued by the IRS which could be easily adopted by the Employer.

[2] I would also urge the IRS to consider the approval of a national defined contribution profit sharing/401(k) plan to ease the document concerns of the Employers. Many adoption agreements are substantially similar and create a lot of expense for Employers when adopting them. A national prototype that provides various options to the participant would provide added assurance to the Employer and streamline the determination letter process.

[3] I am a practitioner in the qualified plan area and utilize volume submitter plans for my clientele.