In Notice 2015-84, the IRS issued the 2015
Cumulative List of Changes in Plan Qualification Requirements. The
2015 Cumulative List is to be used by plan sponsors and
practitioners submitting determination letter applications for
plans during the period beginning Feb. 1, 2016, and ending Jan. 31,
2017.
Plans using the 2015 Cumulative List will primarily be single
employer individually designed defined contribution plans and
single employer individually designed defined benefit plans that
are in Cycle A. Generally, an individually designed plan is in
Cycle A if the last digit of the employer identification number of
the plan sponsor is 1 or 6.
The Cumulative List informs plan sponsors of requirements the IRS
has specifically identified for review in determining whether Cycle
A plans have been properly updated to reflect law changes. Cycle A
plan sponsors may begin submitting their determination letter
applications on Feb. 1, 2016. A plan must comply with all relevant
qualification requirements, not just those on the 2015 Cumulative
List.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.