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Cumulative List of Changes in Retirement Plan Qualification Requirements

The annual Cumulative List of Changes in Retirement Plan Qualification Requirements (Cumulative List) intends to identify, on a remedial amendment cycle basis, all changes in the qualification requirements resulting from changes in statutes, or from regulations or other guidance published in the Internal Revenue Bulletin, that are required to be taken into account in a written retirement plan document that is submitted for a determination letter or an opinion or advisory letter.

Changes beginning in 2017

The 2016 Cumulative List and all subsequent Cumulative Lists will be published only for pre-approved plans prior to the beginning of each 6-year remedial amendment cycle.
For individually designed plans, effective January 1, 2017, Revenue Procedure 2016-37 eliminated the 5-year remedial amendment cycle system. See New Determination Program Rev. Proc. 2016-37. However, third Cycle A filers are still permitted to submit determination letter applications on or before January 31, 2017.

Treasury and the IRS intend to publish annually a Required Amendments List for individually designed plans that generally applies to changes in qualification requirements that become effective on or after January 1, 2016. The Required Amendments List establishes the date that the remedial amendment period expires for changes in qualification requirements contained on the list.  IRS review of determination letter requests for individually designed plans will also be based on the applicable Required Amendments Lists and take into account Cumulative Lists issued prior to 2016..

 

Year

Cumulative List

Cycle

Affected Plans

2015 Notice 2015-84 Cycle A
  • Individually designed plans with an employer identification number ending in 1 or 6
2014 Notice 2014-77 Cycle E
  • Individually designed plans with an employer identification number ending in 5 or 0
  • Governmental plans for which an election has been made
2013 Notice 2013-84 Cycle D
  • Individually designed plans with an employer identification number ending in 4 or 9
  • Multiemployer plans
2012 Notice 2012-76 Cycle C
  • Individually designed plans with an employer identification number ending in 3 or 8
  • Individually designed governmental plans that do not elect to file in Cycle E
  • Pre-approved defined benefit plans

2011

Notice 2011-97

Cycle B

  • Cycle B individually designed multiple employer plans
  • Individually designed plans with an employer identification number ending in 2 or 7
2010 Notice 2010-90

Cycle A

  • Pre-approved defined contribution plans
  • Individually designed plans with an employer identification number ending in 1 or 6
2009

Notice 2009-98

Cycle E

  • Governmental Plans
  • Individually designed plans with an employer identification number ending in 5 or 0

2008

Notice 2008-108

Cycle D

  • Multiemployer plans
  • Individually designed plans with an employer identification number ending in 4 or 9

2007

Notice 2007-94

Cycle C

  • Individually designed plans with an employer identification number ending in 3 or 8

2006

Notice 2007-3

Cycle B

  • Pre-approved defined benefit plans
  • Multiple Employer Plans
  • Individually designed plans with an employer identification number ending in 2 or 7

2005

Notice 2005-101

Cycle A

  • Individually designed plans with an employer identification number ending in 1 or 6 

2004

Notice 2004-84

 
  • Pre-approved defined contribution plans

Additional resources

Page Last Reviewed or Updated: 28-Dec-2016