Institute Comments on Deadline for Using Revised IRS Forms

Washington, DC, February 27, 2002 - The Institute recently submitted a comment letter to the Internal Revenue Service regarding Revenue Procedure 2002-10, which addresses revisions to model and prototype IRA, SEP, and SIMPLE IRA documents. The IRS action comes in light of the statutory changes made by the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) and the proposed changes to the regulations governing required minimum distributions (RMDs) from retirement plans. Under the revenue procedure, existing model forms may not be used to establish new IRAs, SEPs, or SIMPLE IRAs after June 1, 2002.

Given that the revised model forms are not yet available, the Institute urges the IRS to alter the deadline because the June 1 date most likely will not provide adequate time for printing, preparing, and distributing the new forms and accompanying materials to offices and representatives nationwide. The letter also notes that Institute members would need sufficient lead-time to provide training to industry employees and representatives who will be interacting directly with the public concerning the establishment of these accounts.

Specifically, the Institute requests that the deadline for use of the new model forms be the later of December 31, 2002 or 180 days after the IRS officially issues the revised model forms.