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Revisions for pre-approved master and prototype and volume submitter plans

Master and prototype and volume submitter plans

The IRS today released an advance version of Rev. Proc. 2018-21 to modify the procedures for issuing opinion and advisory letters for pre-approved master and prototype and volume submitter plans.

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Rev. Proc. 2018-21 [PDF 52 KB] modifies:

  • Provisions of Rev. Proc. 2015-36 to allow pre-approved defined benefit plans containing a cash balance formula to provide for the actual rate of return on plan assets as the rate used to determine interest credits
  • A provision of Rev. Proc. 2017-41 relating to the rates that are permitted to be used to determine interest credits in pre-approved defined benefit plans containing a cash balance formula
  • References to “hypothetical interest” and “hypothetical interest credits” in Rev. Proc. 2015-36 to “interest credits” to be consistent with the terminology in Rev. Proc. 2017-41

Background

Under a system established in 2005, every individually designed plan qualified under section 401(a) has a regular, five-year remedial amendment cycle. The cycles are staggered and spread over five-year periods, so that plan sponsors need to apply for new determination letters generally only once every five years. 

In addition, under this system, every pre-approved plan (i.e., every master and prototype (M&P) plan and volume submitter (VS) plan) generally has a regular, six-year remedial amendment cycle. Consequently, sponsors, practitioners, and adopters of pre-approved plans generally need to apply for new opinion, advisory, or determination letters only once every six years.

Rev. Proc. 2015-36 [PDF 163 KB] was released in July 2015 to modify earlier guidance by expanding the scope of the pre-approved program to include defined benefit plans containing cash balance features and defined contribution plans containing employee stock ownership plan (ESOP) features. Rev. Proc. 2015-36 also reflected changes made to the determination letter program. 

The IRS in July 2017 released Rev. Proc. 2017-41 [PDF 190 KB] to modify the procedures provided previously by Rev. Proc. 2015-36 for opinion and advisory letters on the form of qualified retirement plans submitted under the pre-approved plan program. On issuing Rev. Proc. 2017-41, the IRS stated that this guidance aimed at simplifying the program by restructuring the master and prototype and volume submitter pre-approved programs into a single program that, in turn, increased the types of eligible plans and allowed greater flexibility in plan design options.

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