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IRS Issues First Required Amendments List for Qualified Plans

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In a previous blog, we discussed the IRS’ elimination of its five year staggered determination letter cycle for individually designed plans.  The IRS recently provided guidance to help sponsors of individually designed plans keep their plans in compliance with applicable law.  Notice 2016-80 contains the first Required Amendments List (the “RA List”) for individually designed qualified retirement plans.  In general, the RA List is a list of changes in the plan qualification requirements for changes that became effective in 2016.  The list is divided into two parts—(A) changes in qualification requirements that would generally require an amendment to most plans  or to most plans of the type affected by the change and (B) changes that the IRS and Treasury anticipate will not require an amendment in most plans, but might require an amendment due to an unusual provision in a particular plan. 

Plan sponsors generally will have until the end of the second calendar year that begins after the issuance of the RA List to amend their plans.  The deadline for plan amendments listed on the 2016 RA List is December 31, 2018.  

Good news for plan sponsors—the 2016 RA List is short.  It does not include any changes that would generally require an amendment in most plans and, it only contains one change in Part B, relating to collectively bargained defined benefit plans. 

The link to the 2016 RA List is here