IRS Issues 2017 Cumulative List of Pre-Approved Plan Requirements

The 2017 cumulative list includes provisions for Roth conversions, using lifetime income products in target-date funds (TDFs) and the use of qualified longevity annuity contracts (QLACs), among other things.

The Internal Revenue Service (IRS) has issued Notice 2017-37, which contains the Cumulative List of Changes in Plan Qualification Requirements for Pre-Approved Defined Contribution Plans for 2017. 

Cumulative Lists identify changes in the qualification requirements of the Internal Revenue Code that are required to be taken into account in a pre-approved plan document submitted under the pre-approved plan program administered by the IRS and that will be considered by the IRS for purposes of issuing opinion letters.

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The 2017 cumulative list includes provisions for Roth conversions, using lifetime income products in target-date funds (TDFs) and the use of qualified longevity annuity contracts (QLACs), among other things.

The 2017 Cumulative List is to be used to submit opinion letter applications for pre-approved defined contribution (DC) plans during the third six-year remedial amendment cycle, which began February 1, 2017, and ends January 31, 2023. Defined contribution plans may be submitted for approval during the on-cycle submission period, which begins October 2, 2017, and ends October 1, 2018.

The IRS no longer issues determination letters for individually designed plans.

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