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CYCLE B Determination Letter Program Opens

On February 1, 2007, the Internal Revenue Service will begin accepting determination letter applications for individually designed plans that fall in “Cycle B” under its system of staggered remedial amendment periods. An individually designed plan is a Cycle B filer if the last digit of the sponsor’s employer identification number is either 2 or 7, or if it is a multiple employer plan (i.e., a non-collectively-bargained plan covering employees of more than one “controlled group” of employers).

Any plan for which a determination letter application is submitted as a part of Cycle B must reflect the changes in qualification requirements and guidance contained in the IRS’ 2006 Cumulative List of Changes in Plan Qualification Requirements. The Cumulative List is published annually and must be taken into account by plans whose remedial amendment period begins on the following February 1st. The text of the 2006 Cumulative List appears in IRS Notice 2007-3, which is available on the IRS web site at http://www.irs.gov/pub/irs-drop/n-07-03.pdf.