List of Pre-Approved Plans
This list includes Master and Prototype (M&P) and Volume Submitter (VS) plans that were submitted to the IRS for opinion or advisory letters:
- Second six-year cycle (PPA) list for defined contribution plans submitted on or after February 1, 2011, for filing under Revenue Procedure 2011-49, covering the 2010 Cumulative List.
The list will be updated periodically. It includes:
- the name of the M&P sponsor or VS practitioner
- the file folder number (FFN) assigned to each plan
- the plan type of each plan submitted
- a letter serial number (LSN) and date. Please note that virtually all of the opinion and advisory letters will be issued at the same time, thus at the date this list is initially issued it will not contain any LSNs or dates.
Determining the type of plan
The third digit of the FFN indicates the type of plan being approved. For example, a number 2 or 3 respectively denote a standardized or nonstandardized M&P; a 5 or 6 depicts a volume submitter plan.
How to use the list
Step 1 - If the employer has adopted, or certified its intent to adopt, an M&P or VS plan, verify that the name of the M&P plan sponsor or VS practitioner appears on the list. If the name does not appear on the list, the employer may not be able to use the plan to restate for the 2010 Cumulative List. An employer who does not adopt a pre-approved plan must restate its plan for the applicable Cumulative List by the end of the applicable 5-year cycle (for individually designed plans).
Step 2 - Determine if the M&P or VS plan that the employer has adopted, or certified its intent to adopt, has received a 2010 Cumulative List opinion or advisory letter. If so, the employer should adopt the approved plan, or take other action as provided in section 17 of Revenue Procedure 2007-44, within the time period described in Step 3, below. If the list does not indicate that a letter has been issued or the application withdrawn, then the application for the 2010 Cumulative List opinion or advisory letter is still pending (i.e., although virtually all of the pre-approved plans will be issued letters at the same time, there may be some applications still pending which will receive a letter with a later date). Sponsors receiving a later letter will not be entitled to any extension of the 2-year window for employer adoption to be announced by the IRS.
Step 3 - The date by which the employer must adopt an approved second-cycle M&P or VS plan, or take other permitted action to comply with the 2010 Cumulative List, is the end of the 2-year window announced by the IRS.
Remedial amendment periods
Qualified plans must be restated for the items identified on the Cumulative List for each respective cycle by the end of their 5-year cycle (individual) or 6-year cycle (pre-approved).
Employers adopting individually designed plans
For an individually designed plan, the remedial amendment period for the items identified on the applicable Cumulative List generally ends on the last day of the plan's applicable 5-year remedial amendment cycle as provided for in section 12.01 of Revenue Procedure 2007-44 (e.g., for a Cycle D plan, no later than January 31, 2015).
Employers adopting pre-approved plans
For an adopting employer of an M&P or VS plan, the remedial amendment period for the items identified on the applicable Cumulative List referenced in the opinion or advisory letter is generally the end of the 2nd applicable 6-year remedial amendment cycle as provided for in section 18.01 of Revenue Procedure 2007-44, or if earlier, the end of the announced period (approximately a two year window) for adopting employers to adopt the final approved version of the pre-approved plan.
The end of a pre-approved defined contribution plan’s remedial amendment cycle with respect to the changes in plan qualification requirements on the 2010 Cumulative List is April 30, 2016. An adopting employer whose defined contribution plan is eligible for the six-year remedial amendment cycle under section 17 of Rev. Proc. 2007–44 by virtue of being a prior adopter, a new adopter, an intended adopter, or an adopter of a replacement plan that meets certain conditions, and who adopts by April 30, 2016, an M&P or VS defined contribution plan that was approved based on the 2010 Cumulative List, will be considered to have adopted the plan within the employer’s six-year remedial amendment cycle. See Announcement 2014-16.
Second six-year cycle
The term "second six-year cycle " refers to the 6-year remedial amendment period for pre-approved plans. For defined contribution plans, the cycle began on February 1, 2011 (following the initial EGTRRA period), incorporating changes enacted by the Pension Protection Act of 2006 (Pub. L. 109-280) and subsequent legislation.
Lists of plans for prior cycles
- EGTRRA cycle list for defined contribution plans submitted on or after February 17, 2005 for filing under Revenue Procedure 2005-16.
- EGTRRA cycle list for defined benefit plans submitted on or after February 1, 2007 for filing under Revenue Procedure 2005-16.
The EGTRRA lists contain the M&P and VS plans that were submitted to the Service for EGTRRA opinion or advisory letters beginning February 1, 2007 (for DB plans) or February 17, 2005 (for DC plans), in accordance with filing procedures under Revenue Procedure 2005-16. The term "EGTRRA" refers to the Economic Growth and Tax Relief Reconciliation Act of 2001, Pub. L. 107-16.
Adopting employers using these pre-approved plan documents to restate a plan for EGTRRA were required to adopt their plans by April 30, 2010 ( Announcement 2008-23), if a DC plan, or by April 30, 2012 (Announcement 2010-20), if a DB plan.
- GUST cycle list for defined contribution and defined benefit plans
The GUST list contain the M&P and VS defined benefit and defined contribution plans that were submitted to the Service for EGTRRA opinion or advisory letters by December 31, 2000, the deadline for filing under of Revenue Procedure 2000-20, as modified by Notice 2001-42.
An employer who adopted, or certified its intent to adopt, a timely-submitted M&P plan or VS specimen plan by the end of the 2001 plan year (December 31, 2001, for calendar-year plans) had until the later of December 31, 2002, or 12 months after the date of the last opinion or advisory letter issued to the M&P plan sponsor or VS practitioner to adopt the GUST amended plan. Also see Announcement 2001-12 for more information.
The term "GUST" refers to the following legislation:
- the Uruguay Round Agreements Act, Pub. L. 103-465
- the Uniformed Services Employment and Reemployment Rights Act of 1994, Pub. L. 103-353
- the Small Business Job Protection Act of 1996, Pub. L. 104-188
- the Taxpayer Relief Act of 1997, Pub. L. 105-34
- the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206
- the Community Renewal Tax Relief Act of 2000, Pub. L. 106-554
- Types of pre-approved retirement plans
- Apply for an opinion or advisory letter
- Determination, Opinion and Advisory Letters