Groom Comments on Proposed IRS 403(b) Prototype Plan Program

On behalf of Diversified Investment Advisors, Groom Law Group has submitted comments to the IRS detailing ways in which the proposed IRS prototype procedure for 403(b) plans in IRS Announcement 2009-34 could be improved, including allowing vesting schedules for employer contributions and certain church-specific provisions.  We also commented on several points in which the language in the proposed List of Required Modifications that accompanied the Notice could be clarified and made more useful.