IRS Issues 2017 Cumulative List of Pre-Approved Plan Requirements

The Internal Revenue Service (IRS) has issued Notice 2017-37, which contains the Cumulative List of Changes in Plan Qualification Requirements for Pre-Approved Defined Contribution Plans for 2017. 

Cumulative Lists identify changes in the qualification requirements of the Internal Revenue Code that are required to be taken into account in a pre-approved plan document submitted under the pre-approved plan program administered by the IRS and that will be considered by the IRS for purposes of issuing opinion letters.

The 2017 cumulative list includes provisions for Roth conversions, using lifetime income products in target-date funds (TDFs) and the use of qualified longevity annuity contracts (QLACs), among other things.

The 2017 Cumulative List is to be used to submit opinion letter applications for pre-approved defined contribution (DC) plans during the third six-year remedial amendment cycle, which began February 1, 2017, and ends January 31, 2023. Defined contribution plans may be submitted for approval during the on-cycle submission period, which begins October 2, 2017, and ends October 1, 2018.

The IRS no longer issues determination letters for individually designed plans.