October 30, 2015, is the extended deadline to submit an on-cycle opinion or advisory letter application for a pre-approved defined benefit plan (Revenue Procedure 2015-36).
The extended deadline of October 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
The defined benefit pre-approved plan program now include pre-approved plans with certain cash balance features. Plans containing cash balance features will not receive favorable opinion letters unless they meet additional requirements related to protection of prior benefit structures and step-rate structures of principal credits. See Revenue Procedure 2015-36, Section 5.16.
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.
- Apply for an Opinion or Advisory Letter - Pre-Approved Retirement Plans
- Tips for Expediting the Determination, Opinion and Advisory Letter Process
- Amend or Update a Plan
- FAQs on determination, opinion or advisory letter issues