In Notice 2014-77, the IRS issued the 2014 Cumulative List of Changes in Plan Qualification Requirements, which is intended for use by plan sponsors of Cycle E individually designed qualified retirement plans and multi-employer plans for the second submission under the remedial amendment cycle described in Rev. Proc. 2007-44.
This list informs plan sponsors of requirements the IRS has identified for review in determining whether Cycle E plans have been properly updated. Cycle D plans primarily include single-employer individually designed defined contribution and defined benefit plans with an employer identification number ending in either 0 or 5.
Cycle E plans also include Section 414(d) plans (including governmental multi-employer or governmental multiple employer plans) for which the plan sponsor has elected to treat Cycle E as the second remedial amendment cycle for the plans. Cycle E plan sponsors may begin submitting their determination letter applications on Feb. 1, 2015. A plan must comply with all relevant qualification requirements, not just those on the 2014 cumulative list.
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