IRS recently updated its Operational Compliance List (OC List) for qualified retirement and 403(b) plans to identify changes in law and guidance affecting plan operations. The OC List doesn’t provide a comprehensive inventory of every item of IRS guidance or new legislation, but reminds plan sponsors about revised operational requirements taking effect during a calendar year, even if conforming amendments are due later. This update to the OC List is the first since June 2020, and notes several revised operational requirements for 2020, along with a few changes taking effect in 2021 and 2022.
Last year, IRS added changes made by the Setting Every Community Up for Retirement (SECURE) Act (Division O of Pub. L. No. 116-94) and the Bipartisan American Miners Act of 2019 (Division M of Pub. L. No. 116-94) to the 2020 OC List. This year, IRS updated the 2020 list to cover additional clarifications issued in Notice 2020-68 and Notice 2020-86. The 2020 list also now includes changes for the Coronavirus Aid, Relief and Economic Security (CARES) Act (Pub. L. No. 116-136) and the additional relief enacted by the 2021 Consolidated Appropriations Act (Division EE of Pub. L. No. 116-260).
The update includes two changes effective in 2021 and one in 2022: