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ARTICLE · 06 OCTOBER 2015

It's The End Of The Determination Letter Program -- As We Know It

Seyfarth Shaw LLP
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With Announcement 2015-19, the Internal Revenue Service has effectively ended the determination letter program for individually designed qualified plans as of January 1, 2017.

United StatesEmployment and HR
Jake Downing
Jake Downing
Fredric Singerman
Fredric Singerman
Randell Montellaro
Randell Montellaro
Diane Dygert
Diane Dygert
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With Announcement 2015-19, the Internal Revenue Service has effectively ended the determination letter program for individually designed qualified plans as of January 1, 2017.  Individually designed plans can still obtain determination letters for the current cycle, ending January 31, 2016, and for Cycle A, which begins February 1, 2016 and ends in January 2017.  As a result, all individually designed plans should be able to receive at least a Pension Protection Act determination letter if they choose.  However, except in the case of a plan's initial qualification or termination, the IRS will no longer issue determination letters to individually designed plans.  Keep in mind this means that an amendment to a plan adopted now, or even adopted in the last few years that was not part of the plan's last determination letter filing, will not fall within the protection of a determination letter for a plan in cycles B, C and D.

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