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Determination, Opinion and Advisory Letter for Retirement Plans - Cumulative List of Changes in Retirement Plan Qualification Requirements

The IRS publishes an annual Cumulative List of Changes in Retirement Plan Qualification Requirements (Cumulative List) around mid-November of each year. The Cumulative Lists are intended to identify, on a year-by-year basis, all changes in the qualification requirements resulting from changes in statutes, or from regulations or other guidance published in the Internal Revenue Bulletin, that are required to be taken into account in the written plan document that is submitted for a determination letter, opinion or advisory letter.

Each annual Cumulative List identifies changes in the qualification requirements that the IRS considers in its review of plans whose submission period begins on the February 1st following issuance of the Cumulative List. For example, sponsors or practitioners maintaining non-mass submitter, mass submitter and national sponsor defined contribution pre-approved plans had until January 31, 2006 to submit opinion and advisory letter applications and the IRS’s review of these plans is based upon the 2004 Cumulative List.

Year	Cumulative List	Cycle	Affected Plans
2012	Notice 2012-76	Cycle C	Individually designed plans with an employer identification number ending in 3 or 8 Individually designed governmental plans that do not elect to file in Cycle E
2011	Notice 2011-97	Cycle B	Cycle B individually designed multiple employer plans Individually designed plans with an employer identification number ending in 2 or 7
2010	Notice 2010-90	Cycle A	Pre-approved defined contribution plans Individually designed plans with an employer identification number ending in 1 or 6
2009	Notice 2009-98	Cycle E	Governmental Plans (one time filing option) Individually designed plans with an employer identification number ending in 5 or 0
2008	Notice 2008-108	Cycle D	Multiemployer plans Individually designed plans with an employer identification number ending in 4 or 9
2007	Notice 2007-94	Cycle C	Individually designed plans with an employer identification number ending in 3 or 8
2006	Notice 2007-3	Cycle B	Pre-approved defined benefit plans Multiple Employer Plans Individually designed plans with an employer identification number ending in 2 or 7
2005	Notice 2005-101	Cycle A	Individually designed plans with an employer identification number ending in 1 or 6
2004	Notice 2004-84		Pre-approved defined contribution plans

For additional information, also see Alert Guidelines, Explanations & Plan Deficiency Paragraphs.

Page Last Reviewed or Updated: 2012-12-20