The IRS today released an advance version of Notice 2020-14 that provides the 2020 cumulative list of changes in plan qualification requirements for purposes of pre-approved defined benefit plans.
The “cumulative list” identifies changes in the qualification requirements that must be taken into account in a pre-approved plan submitted under the pre-approved plan program for consideration by the IRS for purposes of issuing opinion letters.
Notice 2020-14 [PDF 41 KB] provides the “2020 cumulative list.”
In 2016, the IRS issued Rev. Proc. 2016-37 to establish procedures for issuing opinion letters and described the six-year remedial amendment cycle system for pre-approved plans. Pre-approved defined benefit plans and pre-approved defined contribution plans each have separate six-year cycles.
Rev. Proc. 2016-37 also indicated that the IRS would publish cumulative lists identifying changes in the qualification requirements to be considered by the IRS in its review of pre-approved plan documents for purposes of issuing opinion letters. For these purposes a change in the qualification requirements includes a statutory change or a change in the requirements provided in Treasury regulations or other guidance.
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