2022 Retirement Plan Year-End Amendments And Operational Compliance

As the end of 2022 approaches, it's again time for plan sponsors to review their plan documents and plan operations to ensure compliance with increasingly complex qualification requirements and moving deadlines.  While there are few, if any, required plan amendments for 2022, plan sponsors must remain diligent about amendment deadlines, operational compliance with changes in law, and ensuring later-adopted plan amendments accurately reflect plan operations.

Year-End Plan Amendments

Plan amendments may be needed before the end of 2022 for plan design changes and in limited cases, for changes in law:

• 2022 Plan Design Changes. Generally, plan documents should be amended by plan year-end for any “discretionary” changes implemented during 2022.  These discretionary changes may include plan design changes (other than required compliance amendments described below), changes in plan administration impacting the plan document, and changes to plan provisions pursuant