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.
