The IRS announced (Announcement 2015-19) important changes to the employee plans determination letter program for qualified retirement plans. Effective Jan. 1, 2017, the IRS will eliminate the staggered five-year determination letter remedial amendment cycles for individually designed plans. Beginning on that date, the IRS will limit the determination letter program for individually designed plans to initial plan qualification and qualification upon plan termination. However, sponsors of Cycle A plans can still submit determination letter applications during the period beginning Feb. 1, 2016, and ending Jan. 31, 2017. Cycle A plans include individually designed single-employer plans sponsored by an entity with an employer identification number ending in either 1 or 6 and defined contribution pre-approved plans (i.e., defined contribution plans that are master and prototype or volume submitter plans).
The IRS also announced that effective July 21, 2015, it no longer accepts determination letter applications that are submitted off-cycle, with certain exceptions.
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