New DocsEngine for Pension Update for Elimination of Five-year Amendment Cycles
Effective January 31, 2017, the Internal Revenue Service (IRS) clarified and modified its qualified plan determination letter program by eliminating the five-year remedial amendment cycle for individually-designed plans. Consequently, the IRS will only accept applications for approval in the following circumstances:
Initial plan qualification
Qualification upon plan termination
Other circumstances for amended plans considered valid by the IRS at the time of the filing or as announced in published guidance.
Effective immediately, all references to “Cycles” have been eliminated from the ESOP, KSOP and Cash Balance Plans and each plan is current for the changes required by the 2015 Cumulative List of Changes (IRS Notice 2015-84) and the 2016 Required Amendment List for Qualified Retirement Plans (IRS Notice 2016-80).
Considering these new rules and their overlap with the third five-year Cycle A filing, the IRS accepted determination letter filings until the January 31, 2017 deadline in accordance with previously established guidelines.
A full explanation of the new filing guidelines and the redefined remedial amendment period for disqualifying provisions can be found at Revenue Procedure 2016-37.
What is New in this Release?
This update contains the following items:
How do I access the updated versions of these documents?
When you next create an ESOP or KSOP plan, you will automatically be using the latest and most up-to-date templates, and you do not need to take any additional steps to access the new versions of these two documents.
When you next want to create a Cash Balance Plan, you would access the "Current Documents" document group (as you normally would), and instead of seeing options for the "PPA" and "3rd 5-Year Cycle" Cash Balance plans, you will see one option called "Cash Balance Plan (Post Cycles)". Select this document type, and you will be accessing the most up-to-date plan.
Have a Question or Need Information?
As always, if you have any questions on this new update, feel free to contact us at 877-346-5994 or firstname.lastname@example.org.