It has been a while since I jumped on the blogging trail, but the question "What comes first, the Written Plan or the Implementation Date?" seems more and more like... "the Chicken and the egg."
Taking this one step at a time, there are a significant number of employer/plan sponsors, administrators and others tackling this question. I have had a number of conversations with individuals and groups that began pulling together the "Written Plan" for their 403(b) plan(s) and were simply stumped when posed with defining the original start date of the plan. I have found this question alone can be the primary reason a "written plan" was not finalized for some 403(b) plans.
Once we get past the "chicken and egg" conversation, the conversation progresses to somewhat of a dart board effect. Well, a reasonable guess would be to date the plan as of 01-01-2009, but your investments would possibly age prior to that date. Another reasonable guess is the oldest date on the first investment contract or account holding current assets. There is a solid argument for this approach, but it can result in a bit of an art, rather than a science.
Sometimes the right answer is very much tied to your facts and circumstances, within reason. If you can identify the date of the first contribution or funding to your 403(b) plan, begin there and work forward. Read on for additional challenges that have surfaced while capturing the "written plan"...
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