Pension Protection Act

This is a new subject to me. I have been asked by bank management to look into the disclosure change requirements for IRA account customers and discover any revisions that need to be made.

Can anyone help direct me to the proper information? I do not know where to find model language from up-dating IRA disclosures.

Any advice?

Thank you

We have just purchased our new disclosures from Wolters Kluwer. The changes actually cover several new acts in addition to Pension Protection Act.

Are these disclosures ones that we are required to give a customer who opens an IRA at our bank or are they for employees of the bank for wich the bank is furnishing the retirement plan.

New disclosure are not required at this time.

There is no official checklist for what the plain language disclosure must include; you will find significant variations among the disclosures produced by forms vendors. The closest you will come to a model disclosure on this subject is IRS Publication 590 and the current version is for the 2005 tax year; i.e. it does not contain recent changes.

I suggest that the plain language disclosure should be as current as possible at the time it is distributed. Nevertheless, distribution of the current Publication 590 constitutes distribution of the required disclosure - there is no specific requirement that the disclosure be up to the minute.

My suggestion is that you buy current disclosures from a vendor -there is no way you could cost justify the time and research involved in writing them yourself. Distribute the revised disclosures at account inception, but avoid "the big lie;" there is no requirement that you distribute revised disclosures to existing IRA account holders due to the changes made by the Pension Protection Act.