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IRS Determination Letter Program

In a previous quarterly report, MJM401k advised that the IRS was planning substantial curtailments to its individually designed plan determination letter program, due to budgetary constraints. That curtailment has now become official. Effective January 1, 2017, individually designed plans may apply for a determination letter only upon inception, termination, or “certain other circumstances”. The other circumstances may include significant law changes, etc., but will depend on the IRS’s available resources at the relevant time. The IRS intends to publish on an annual basis both a “Required Amendments List” and an “Operational Compliance List” to define future required amendments and their required adoption dates, and to promote operational compliance for sponsors of individually designed plans.