Expansion of IRS determination letter program for individually designed plans

Beginning on Sept. 1, 2019, the IRS will reopen its determination letter program for cash balance plans on a temporary basis and for certain merged plans on an ongoing basis.

• The determination letter program will be expanded to permit plan sponsors to submit determination letter applications for individually designed statutory hybrid plans (aka cash balance plans) during the 12 month period beginning Sept. 1, 2019 and ending Aug. 31, 2020
• Plan sponsors may submit determination letter applications for certain merged plans beginning on Sept. 1, 2019 and will be accepted on an ongoing basis

Since 2017, the determination letter program has only been available for initial plan qualification or qualification upon plan termination. The IRS provides applicable procedures and instructions on the exercise of this expansion in Revenue Procedure 2019-20. If you have questions about the determination letter program, in general or specific to this expansion, please contact a member of Plante Moran’s employee benefits consulting group.