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Deadline Extended For Pre-Approved Defined Benefit Plans

June 30, 2015, is the extended deadline to submit an on-cycle opinion or advisory letter application for a pre-approved defined benefit plan (Announcement 2014-41). Without this extension, these applications would have been due February 2, 2015 (Announcement 2014-4).

The extended deadline of June 30, 2015, applies to all pre-approved defined benefit plans, even if they won’t be modified to include cash balance features. These plans include:

  • mass submitter lead and specimen plans;
  • word-for-word identical plans;
  • master and prototype minor modifier placeholder applications; and
  • non-mass submitter plans.

Plans submitted by the extended due date will be reviewed for qualification items based on the 2012 Cumulative List.

Plans with cash balance features

We intend to expand the defined benefit pre-approved plan program to include pre-approved plans with certain cash balance features. This extended deadline will give us time to develop the necessary language and tools to process pre-approved cash balance plans and for practitioners to prepare their plans for submission.

Guidance will be issued in the future to announce:

  • cash balance features that will be permitted under the pre-approved program, and
  • when applications for opinion and advisory letters may be submitted for plans with cash balance features.

Until the future guidance is issued, plans with cash balance features should not be submitted under the pre-approved program.


Please email us any comments you may have on the expansion of the pre-approved defined benefit program to include plans with cash balance features, for example:

  • comments on program parameters, and
  • proposals for sample plan language.

Please direct your email to the attention of Don Kieffer.

Additional resources

Page Last Reviewed or Updated: 19-Mar-2015