Providers of Pre-Approved Documents Have Longer to File for Opinion Letter

The Internal Revenue Service (IRS) has published Revenue Procedure 2018-42 to extend the deadline for submitting on-cycle applications for opinion letters for pre-approved defined contribution (DC) plans for the third six-year remedial amendment cycle to December 31, 2018.   

Under Rev. Proc. 2017-41, this submission period is scheduled to expire on October 1, 2018.

The IRS notes that Rev. Proc. 2017-41 modified the pre-approved letter program by combining the master & prototype and volume submitter programs into a new opinion letter program. Under this program, providers of pre-approved plans may apply for new opinion letters once every six years.