IRS Opens Window to Adopt Updated Pre-Approved Plans

Retirement plan sponsors have a two-year window to adopt newly updated pre-approved plan documents.

In Announcement 2014-16, the Internal Revenue Service says it will soon issue opinion and advisory letters for pre-approved master and prototype (M&P) and volume submitter (VS) defined contribution plans that were restated for changes in plan qualification requirements listed in the 2010 Cumulative List and filed with the Service during their second submission period under the remedial amendment cycle (see “IRS Publishes Changes in Plan Qualification Requirements”). The Service expects to issue the letters on March 31, 2014, or, in some cases, as soon as possible thereafter.

Employers using these pre-approved plan documents to restate a plan for the plan qualification requirements on the 2010 Cumulative List will be required to adopt the plan document by April 30, 2016. Starting May 1, 2014 and ending April 30, 2016, the Service will accept applications for individual determination letters from employers under the second six-year remedial amendment cycle for defined contribution pre-approved plans.