The IRS has issued the 2012 Cumulative List of Changes in Plan Qualification Requirements (Notice 2012-76), which is intended for use by plan sponsors of Cycle C individually designed qualified retirement plans for the second submission under the remedial amendment cycle described in Rev. Proc. 2007-44.

The list informs plan sponsors of requirements the IRS has specifically identified for review in determining whether Cycle C plans have been properly updated. Cycle C plans primarily include single-employer individually designed defined contribution plans and defined benefits plans with an employer identification number ending in either 3 or 8. Cycle C plans also include Section 414(d) government plans that choose to file during Cycle C. Cycle C plan sponsors may begin submitting their determination letter applications on Feb. 1, 2013. A plan must comply with all relevant qualification requirements, not just those on the 2012 cumulative list.

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