Employee Benefits-IRS Issues 2015 Cumulative List Of Changes In Plan Qualification Requirements

The IRS has issued Notice 2015-84 (the “Notice”), which contains the 2015 Cumulative List of Changes in Plan Qualification Requirements (the “2015 Cumulative List”) described in section 4 of Rev. Proc. 2007- 44. Here is what the IRS said in this Notice.

The 2015 Cumulative List is to be used by plan sponsors and practitioners submitting determination letter applications for qualified retirement plans 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. 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.

In accordance with Rev. Proc. 2007-44, the IRS will start accepting determination letter applications for Cycle A individually designed plans beginning on February 1, 2016. The 12-month submission period for Cycle A plans will end on January 31, 2017. The 2015 Cumulative List, set forth in section IV of this Notice, informs plan sponsors of issues the IRS has specifically identified for review in determining whether a plan filing in Cycle A has been properly updated.

See the Notice for the new list of changes and other details.