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Rev. Proc. 2020-9

SECTION 3. CLARIFICATION OF

Internal Revenue Bulletin 2020-2 · 2026-10-03 edition · updated 2026-10-04 · United States

INTEGRAL AMENDMENT RULES AND EXTENSION OF INTERIM AMENDMENT DEADLINE

.01 This section 3 clarifies which amendments are treated as integral to a plan provision that fails to satisfy the Final Regulations and extends the plan amendment deadline provided in section 15.04 of Rev. Proc. 2016-37, applicable to interim amendments with respect to required amendments described in section 2.03 of this revenue procedure, and all amendments treated as integral to those amendments.

.02 All plan amendments that relate to a plan’s hardship distribution provisions and that are effective no later than January 1, 2020, are treated as integral to the required amendments described in section 2.03 of this revenue procedure. This treatment applies even if the required amendments are implemented earlier than for hardship distributions made on or after January 1, 2020.

.03 Pursuant to section 15.05 of Rev. Proc. 2016-37, the deadline, applicable to pre-approved plans, for adopting interim amendments with respect to the required amendments described in section 2.03 of this revenue procedure and all amendments that are integral to those amendments (as described in section 3.02 of this revenue procedure) is extended to December 31, 2021.

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