In Notice 2015-84
, the IRS issued the 2015 Cumulative List of Changes in Plan Qualification Requirements. The 2015 Cumulative List is to be used by plan sponsors and practitioners submitting determination letter applications for plans during the period beginning Feb. 1, 2016, and ending Jan. 31, 2017.
Plans using the 2015 Cumulative List will primarily be single employer individually designed defined contribution plans and single employer individually designed defined benefit plans that are in Cycle A. Generally, an individually designed plan is in Cycle A if the last digit of the employer identification number of the plan sponsor is 1 or 6.
The Cumulative List informs plan sponsors of requirements the IRS has specifically identified for review in determining whether Cycle A plans have been properly updated to reflect law changes. Cycle A plan sponsors may begin submitting their determination letter applications on Feb. 1, 2016. A plan must comply with all relevant qualification requirements, not just those on the 2015 Cumulative List.
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