Pension & Benefits News IRS issues guidance on third six-year remedial amendment cycle for pre-approved DB plans
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Wednesday, January 15, 2020

IRS issues guidance on third six-year remedial amendment cycle for pre-approved DB plans

By Pension and Benefits Editorial Staff

The IRS has announced that the third six-year remedial amendment cycle for pre-approved defined benefit plans begins on May 1, 2020 and ends on January 31, 2025. The IRS further states that the on-cycle submission period for providers to submit applications for opinion letters for pre-approved defined benefit plans begins on August 1, 2020 and ends on July 31, 2021. When the IRS review process for pre-approved defined benefit plans for the third six-year remedial amendment cycle has neared completion, the IRS will announce the date by which adopting employers must adopt the newly approved plans and, if they are otherwise eligible, apply for an individual determination letter.

Background. In Rev. Proc. 2016-37, the IRS provides that every pre-approved defined benefit plan has a regular, six-year remedial amendment cycle. The third six-year remedial cycle was scheduled to span February 1, 2019 to January 31, 2025, according to the IRS. IRS Announcement 2018-05 extended the end date for the second remedial cycle from January 31, 2019 to April 30, 2020 and stated that the IRS would announce in future guidance the delayed starting date for the third six-year remedial amendment cycle.

Providers of pre-approved plans may apply for new opinion letters once every six years under Rev. Proc. 2017-41. Rev. Proc. 2017-41 sets forth the procedures for obtaining opinion letters for qualified pre-approved plans submitted with respect to the third (and subsequent) six-year remedial amendment cycles.

Source: Rev. Proc. 2020-10.

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