The IRS on Dec. 14 issued the 2015 Cumulative List of Changes in Plan Qualification Requirements. The list, contained in Notice 2015-84, is to be used by plan sponsors and practitioners submitting determination letter applications for plans during the period beginning Feb. 1, 2016 and ending Jan. 31, 2017.
Plans using this 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.
The list of changes in Notice 2015-84 does not extend the deadline by which a plan must be amended to comply with any statutory, regulatory or guidance changes.
Plans using this Cumulative List primarily will 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.
The list of changes in section IV of this notice does not extend the deadline by which a plan must be amended to comply with any statutory, regulatory, or guidance changes. The general deadline for timely adoption of an interim or discretionary amendment can be found in section 5.05 of Rev. Proc. 2007-44.
Except as provided in the notice, the IRS will not consider in its review of any determination letter application for the submission period that begins Feb. 1, 2016, any of the following:
Plans using this 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.
The list of changes in Notice 2015-84 does not extend the deadline by which a plan must be amended to comply with any statutory, regulatory or guidance changes.
Plans using this Cumulative List primarily will 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.
The list of changes in section IV of this notice does not extend the deadline by which a plan must be amended to comply with any statutory, regulatory, or guidance changes. The general deadline for timely adoption of an interim or discretionary amendment can be found in section 5.05 of Rev. Proc. 2007-44.
Except as provided in the notice, the IRS will not consider in its review of any determination letter application for the submission period that begins Feb. 1, 2016, any of the following:
- guidance issued after Oct. 1, 2015;
- statutes enacted after Oct. 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 this notice; or
- proposed regulations or other guidance described solely in any footnote in this notice.
- However, in order to be qualified, a plan must comply with all relevant qualification requirements, not just those on the 2015 Cumulative List.
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