Plan sponsors that are scheduled to file determination letter applications with the IRS for their qualified retirement plans between February 1, 2015 and January 31, 2016, (Cycle E sponsors), should be aware that the IRS recently released its 2014 cumulative list of plan changes. The list, contained in IRS Notice 2014-77, includes required and optional changes to plan qualification requirements that should to be reflected in plan documents submitted to the IRS for review.
The 2014 list mainly applies to single employer defined contribution and defined benefit plans and includes plan changes from IRS cumulative lists dating back to 2010. Some new changes for the 2014 cumulative list include, among other things, guidance on the application of the Supreme Court’s decision in U.S. v. Windsor, certain safe harbors for rollover contributions, and changes to the required minimum distribution rules for plans that offer longevity annuities. Plan sponsors should refer to the list when preparing Cycle E determination letter applications and confirm that all applicable required changes have been adopted by the appropriate deadlines.
