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#2152424 - 11/06/17 08:20 PM 2017 IRA changes requiring disclosures?
Oh My!!! Offline
100 Club
Oh My!!!
Joined: Apr 2005
Posts: 112
Illinois
I am aware of the recent changes to IRAs. I have been told banks have been called by companies that provide preprinted notices and disclosures, about a required notice that must be sent to customers? I can't find anything regarding a required notice. I'm hoping someone here has some idea what they are referring to? Thanks!

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General Discussion
#2152425 - 11/06/17 08:38 PM Re: 2017 IRA changes requiring disclosures? Oh My!!!
Sunshine Lady Offline
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Sunshine Lady
Joined: Apr 2014
Posts: 680
What Are the Changes?
o Traditional IRA 5305s: Financial organizations will now collect an “account number” rather than the account owner’s social security number. The removal of the account owner’s social security number, even though it is still collected on the IRA application, is designed to help reduce identity theft. Additionally, Article I of the document was updated to reflect the 2017 maximum contribution limits and Article VIII was modified to clarify that a financial organization cannot imply that any provisions added to that article have been reviewed or preapproved by the IRS, an important addition as the IRS now expressly prohibits implying that the IRS reviewed or approved all of the articles of the 5305. Last, the General Instructions on the form have been updated to reflect these changes. The instructions also now list IRS Publications 590-A, Contributions to Individual Retirement Arrangements (IRAs) and 590-B, Distributions from Individual Retirement Arrangements (IRAs), as an additional source of information.
o Roth IRA 5305s: In addition to the same or equivalent changes made to the traditional IRA 5305s, the IRS amended Article I to update the modified adjusted gross income (MAGI) limits that determine Roth IRA regular contribution eligibility. The IRS also removed from Article II language that limited Roth IRA conversion contributions. The General Instructions on the form have been updated accordingly.
o SIMPLE IRA 5305s: In addition to changes made to the traditional IRA 5305s relating to collecting an account number in place of the account owner’s social security number the IRS added language clarifying when transfers and rollovers from an eligible retirement plan can be accepted into a SIMPLE IRA. The IRS also modified Article VIII to clarify that a financial organization cannot imply that any provisions added to that article have been reviewed or preapproved by the IRS. The General Instructions on the form have been updated accordingly.
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Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney

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#2152426 - 11/06/17 08:43 PM Re: 2017 IRA changes requiring disclosures? Oh My!!!
Oh My!!! Offline
100 Club
Oh My!!!
Joined: Apr 2005
Posts: 112
Illinois
Thanks! I was aware of the changes, but not that any notification to the customer was required.

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#2152437 - 11/06/17 09:53 PM Re: 2017 IRA changes requiring disclosures? Oh My!!!
Sunshine Lady Offline
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Sunshine Lady
Joined: Apr 2014
Posts: 680
I do not know if it is required either, but we are going to notify our existing customers.
_________________________
Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney

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#2152439 - 11/06/17 09:55 PM Re: 2017 IRA changes requiring disclosures? Oh My!!!
Bankwoman1 Offline
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Joined: Dec 2015
Posts: 1,064
Midwest
If you have a forms vendor that you deal with they may be able to help you with an amendment to send to your customers. We deal with Wolters Kluwer and they have already contacted us about amendments to provide to our IRA customers.

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#2152458 - 11/07/17 10:40 AM Re: 2017 IRA changes requiring disclosures? Bankwoman1
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
You should begin using the new 5305 (IRA plan) forms, accompanied by a "current" disclosure, for new customers now.

None of the "changes" to the 5305 forms reflected in the vendor's synopsis Sunshine Lady posted reflect new legal requirements or restrictions other than those that are subject to annual adjustment; i.e. they have no impact on existing IRA participants. If the IRS wants you to send a copy of the revised plan (Form 5305) to existing participants they will issue guidance to that effect as they have with prior revisions. (The most recent revision was 15 years ago.)

Unless you use IRS publications 590 A & B, the "plain language disclosures" are generally "updated" on the whim of the vendor that publishes them. As the recent changes to the 5305 forms do not drive any changes to the disclosures, you are under no obligation to provide existing IRA participants with a new disclosure.

If you are going to ask a forms vendor for advice about doing a mass mailing to existing customers, ask for a citation to law, regulation, or IRS guidance that supports any direction to do the mailing. Otherwise, it's like asking the people at Valvoline how often you should change the oil in your car. Valvoline makes money by selling oil, not by giving advice. Forms vendors...
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