Prototype IRAs Announcement 2022-6 provides, "[E]ffective March 14, 2022, and until further notice, the Internal Revenue Service (IRS) will not accept applications for opinion letters on prototype IRAs (traditional, Roth and SIMPLE IRAs)." As stated in Revenue Procedure 2010-48 and Announcement 2022-6, prototype IRAs do not need to amend for various law changes since 2002 for the trustee, custodian or issuer to take advantage of them. These "statutory changes" are listed in the revenue procedure. A prototype IRA that does amend to incorporate the statutory changes may continue to rely on its favorable opinion letter. Taxpayers may use existing model forms to maintain current plans and accounts or establish new plans and accounts. Although not currently required, the IRS recommends that the plan sponsor adopt the model's latest form once these are available. Model IRAs Model IRAs do not need to amend for the statutory changes. The IRS expects to issue new model amendments for: SIMPLE individual retirement annuity; traditional individual retirement annuity; and Roth individual retirement accounts Although not currently required, the IRS recommends that the plan sponsor adopt the model’s latest form once these are available.
