IRS Publishes Updated Operational Compliance Checklist - 2021

The IRS recently updated its Operational Compliance Checklist (the "Checklist") to include qualification requirements that will become effective during the 2021 and 2022 calendar years. Examples of items added to the Checklist for 2021 and 2022 include, among other things:

• Final regulations relating to updated life expectancy and distribution tables used for determining minimum required distributions;
• The SECURE Act requirement that qualified cash or deferred arrangements must allow long-term employees (i.e., employees who work at least 500 but less than 1,000 hours per year for three consecutive 12-month periods beginning on or after January 1, 2021) to participate; and
• Temporary relief from the physical presence requirement for spousal consents under qualified retirement plans.

The Checklist is only available online and is updated periodically to reflect new legislation and IRS guidance. The Checklist does not, however, include routine, periodic changes, such as cost-of-living increases, spot segment rates, and applicable mortality tables, which can instead be found on the IRS's Recent Published Guidance webpage here. The Checklist is available here.