IRS Releases 2015 Cumulative List

The list of changes in plan qualification requirements is used by retirement plan sponsors and practitioners submitting determination letter applications for their plan documents.

The Internal Revenue Service (IRS) issued Notice 2015-84, containing the 2015 Cumulative List of Changes in Plan Qualification Requirements (2015 Cumulative List) described in section 4 of Rev. Proc. 2007-44. 

The 2015 Cumulative List is to be used by plan sponsors and practitioners submitting determination letter applications for plan documents during the period beginning February 1, 2016, and ending January 31, 2017. Plans using this Cumulative List will primarily be single employer individually designed defined contribution plans and single employer individually designed defined benefit plans that are in Cycle A. Generally, an individually designed plan is in Cycle A if the last digit of the employer identification number of the plan sponsor is 1 or 6.                        

In the Notice, the IRS says the 2015 Cumulative List reflects law changes under the Pension Protection Act of 2006 (PPA); the Worker, Retiree, and Employer Recovery Act of 2008 (WRERA); the Small Business Jobs Act of 2010 (SBJA); the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010 (PRA 2010); the Moving Ahead for Progress in the 21st Century Act (MAP-21); the American Taxpayer Relief Act of 2012 (ATRA); the Highway and Transportation Funding Act of 2014 (HATFA); the Cooperative and Small Employer Charity Pension Flexibility Act (CSEC Act); the Consolidated and Further Continuing Appropriations Act, 2015; and the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015.

Except as otherwise provided, the IRS will not consider in its review any:

  • guidance issued after October 1, 2015; 
  • statutes enacted after October 1, 2015;
  • qualification requirements first effective in 2017 or later;
  • statutory provisions that are first effective in 2016, for which there is no guidance identified in its notice; or
  • proposed regulations or other guidance described solely in any footnote in the notice.

In January, the IRS proposed that effective January 1, 2017, the scope of the determination letter program for individually designed plans will be limited to initial plan qualification and qualification upon plan termination.

Text of Notice 2015-84 is here.