Employee Benefits-IRS Issues 2012 Cumulative List of Changes in Plan Qualification Requirements

December 13, 2012

The Internal Revenue Service has issued Notice 2012-76, which contains the 2012 Cumulative List of Changes in Plan Qualification Requirements (the "2012 Cumulative List"). This list is described in section 4 of Rev. Proc. 2007-44.

The 2012 Cumulative List is to be used by plan sponsors and practitioners, submitting determination letter applications for plans during the period beginning February 1, 2013 and ending January 31, 2014, to determine the provisions that the plans must contain. Plans using the 2012 Cumulative List will include single employer individually designed defined contribution plans and defined benefit plans that are in Cycle C. Generally, an individually designed plan is in Cycle C if the last digit of the employer identification number of the plan sponsor is 3 or 8. In addition, the 2012 Cumulative List will be used by sponsors of defined benefit pre-approved plans (that is, defined benefit plans that are master and prototype (M&P) or volume submitter (VS) plans) for the second submission under the remedial amendment cycle described in Rev. Proc. 2007-44.