IRS extends deadline for pre-approved DC plan six-year cycle opinion letter procedures

The IRS has extended the deadline for submitting on-cycle opinion letter applications for pre-approved defined contribution plans for the third six-year remedial amendment cycle to December 31, 2018. This revenue procedure is effective as of August 15, 2018. Under Rev. Proc. 2017-41, this submission period was scheduled to begin on October 2, 2017 and to end on October 1, 2018.

Rev. Proc. 2017-41 modified the IRS’s approach to pre-approved plans by eliminating the distinction between master and prototype (M&P) and volume submitted (VS) programs and combining the two into a new opinion letter program. Under this new program, providers of pre-approved plans may apply for new opinion letters once every six years. In addition, IRS has expanded the types of plans eligible for pre-approved status to afford greater flexibility in the design of pre-approved plans.

Rev. Proc. 2017-41 is modified by revising sections 1.02, 3.10, and 9.02 to replace October 1, 2018 with December 31, 2018.

Source: Rev. Proc. 2018-42.
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