These lists include Pre-Approved, Master and Prototype (M&P) and Volume Submitter (VS) plans that were submitted to the IRS for opinion or advisory letters: Defined benefit plans The third remedial amendment cycle (RAC) list PDF is for defined benefit plans submitted from August 1, 2020, to May 13, 2024 and covers the 2020 Cumulative List. Rev. Proc. 2017-41 changed the pre-approved program so that M&P and VS plans are combined into a single opinion letter program. Additionally, the types of plans are now reflected simply as either standardized or non-standardized pre-approved plans. The list will be updated periodically. It includes: the name of the Pre-approved Plan Provider, the file folder number (FFN) assigned to each plan, the plan type of each plan submitted, and a letter serial number (LSN) and date. Please note that virtually all opinion letters were issued at the same time February 28, 2023. The third RAC list contains the pre-approved plans that were submitted to the Service for opinion letters beginning August 1, 2020, to May 13, 2024, according to Revenue Procedure 2017-41. Adopting employers who use these pre-approved plan documents to restate their plan for the 2020 Cumulative List are required to adopt the plan by March 31, 2025. See Announcement 2023-6. Defined contribution plans The third remedial amendment cycle (RAC) list PDF is for defined contribution plans submitted from October 2, 2017, to May 13, 2024, and covers the 2017 Cumulative List. Rev. Proc. 2017-41 changed the pre-approved program so that M&P and VS plans are combined into a single opinion letter program. Additionally, the types of plans are now reflected as either standardized or nonstandardized. Additionally, the types of plans are now reflected simply as either standardized or non-standardized pre-approved plans. The list may be updated periodically. It includes: the name of the Pre-approved Plan Provider, the file folder number (FFN) assigned to each plan, the plan type of each plan submitted, and a letter serial number (LSN) and date. Please note that virtually all opinion letters were issued at the same time, June 30, 2020. The third RAC list contains the pre-approved plans that were submitted to the Service for opinion letters beginning October 2, 2017 according to Revenue Procedure 2017-41 (later modified by Revenue Procedure 2018-42). Adopting employers who use these pre-approved plan documents to restate their plan for the 2017 Cumulative List were required to adopt the plan by July 31, 2022. See Announcement 2020-7. Defined benefit plans The second remedial amendment cycle (also referred to as PPA cycle) PDF is a list of defined benefit plans submitted from February 1, 2013, to October 30, 2015, and is based on the 2012 Cumulative List. The term "PPA” refers to the Pension Protection Act of 2006, Pub. L. 109-280. The list will be updated periodically and includes: the name of the M&P sponsor or VS practitioner, the file folder number (FFN) assigned to each plan, the plan type of each plan submitted, a letter serial number (LSN) and date. Please note that virtually all opinion and advisory letters were issued at the same time. The PPA list contains the M&P and VS plans that were submitted to the Service for opinion or advisory letters beginning February 1, 2013 according to Revenue Procedure 2011-49 (later modified and superseded by Revenue Procedure 2015-36, which was subsequently modified by Revenue Procedure 2018-21). Adopting employers who used these pre-approved plan documents to restate their plan for PPA were required to adopt the plan by July 31, 2020. See Announcement 2018-05 as modified by Notice 2020-35. Defined contribution plans The second six-year cycle (PPA) list PDF is for defined contribution plans submitted from February 1, 2011, to April 2, 2012, and covers the 2010 Cumulative List. The list will be updated periodically. It includes: the name of the M&P sponsor or VS practitioner, the file folder number (FFN) assigned to each plan, the plan type of each plan submitted, and a letter serial number (LSN) and date. Please note that virtually all opinion and advisory letters were issued at the same time. Generally, adopting employers used these pre-approved plan documents to restate their plans for PPA starting April 1, 2014 through April 30, 2016. Adopting employers could also apply for a determination letter (if eligible) starting May 1, 2014 through April 30, 2016. See Announcement 2014-16. However, this deadline was extended to April 30, 2017 for newly-approved pre-approved defined contribution plans that were first adopted on or after January 1, 2016. See Revenue Procedure 2016-37. See also: Pre-Approved 403(b) Plans for a list of 403(b) pre-approved plans. Determining the type of plan The third digit of the FFN indicates the type of plan being approved. A number 7 indicates a third cycle pre-approved plan. To determine whether a third cycle plan is standardized or nonstandardized, look at the plan type column of the list. For prior cycles the numbers 2 or 3 respectively denote a standardized or nonstandardized M&P plan; a 5 or 6 depicts a volume submitter plan. How to use the list Step 1 - If the name of the pre-approved plan provider, M&P plan sponsor, or VS practitioner is on the list, an adopting employer of a pre-approved plan can verify that the plan can be used to restate for the applicable Cumulative List. If the name isn’t on the list, the adopting employer should contact its pre-approved plan provider/sponsor/practitioner to determine why its name isn’t on the list, as the adopting employer may not be able to use the plan to restate for the applicable Cumulative List. Step 2 - Determine if the pre-approved plan adopted by the employer has received an opinion or advisory letter. If so, the employer should adopt the approved plan or take other action as provided in section 19 of Revenue Procedure 2016-37 during the time described in Step 3 below. If the list does not indicate that a letter has been issued, the application for the opinion or advisory letter could still be pending. Almost all the letters for pre-approved plans were issued at the same time, but there may be some applications still pending. Sponsors receiving a late letter will not be entitled to any extension of the 2-year window for employers to adopt the pre-approved plan. Step 3 - The employer must adopt an approved second-cycle M&P or VS plan or a third cycle pre-approved plan by the end of the 2-year window announced by the IRS. See discussion of deadlines at Pre-approved Retirement Plans - Adopting Employer. Lists of plans for prior cycles EGTRRA EGTRRA cycle list for defined contribution plans PDF covers plans submitted on or after February 17, 2005 for filing under Revenue Procedure 2005-16. EGTRRA cycle list for defined benefit plans PDF covers plans submitted on or after February 1, 2007 for filing under Revenue Procedure 2005-16. The EGTRRA lists contain the M&P and VS plans that were submitted to the Service for EGTRRA opinion or advisory letters beginning February 1, 2007 (for DB plans) or February 17, 2005 (for DC plans), in accordance with filing procedures under Revenue Procedure 2005-16. The term "EGTRRA" refers to the Economic Growth and Tax Relief Reconciliation Act of 2001, Pub. L. 107-16. Adopting employers who used these pre-approved plan documents to restate their plan for EGTRRA were generally required to adopt the plan by April 30, 2010 for DC plans or April 30, 2012 for DB plans. See Announcement 2008-23 and Announcement 2010-20. GUST GUST cycle list PDF covers defined contribution and defined benefit plans. The GUST list contains the M&P and VS defined benefit and defined contribution plans that were submitted to the Service for EGTRRA opinion or advisory letters by December 31, 2000, the deadline for filing under of Revenue Procedure 2000-20, as modified by Notice 2001-42. An employer who adopted, or certified its intent to adopt, a timely-submitted M&P plan or VS specimen plan by the end of the 2001 plan year (December 31, 2001, for calendar-year plans) had until the later of December 31, 2002, or 12 months after the date of the last opinion or advisory letter issued to the M&P plan sponsor or VS practitioner to adopt the GUST amended plan. See Announcement 2001-12 for more information. The term "GUST" refers to the following legislation: the Uruguay Round Agreements Act, Pub. L. 103-465 the Uniformed Services Employment and Reemployment Rights Act of 1994, Pub. L. 103-353 the Small Business Job Protection Act of 1996, Pub. L. 104-188 the Taxpayer Relief Act of 1997, Pub. L. 105-34 the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206 the Community Renewal Tax Relief Act of 2000, Pub. L. 106-554 Additional resources: Revenue Procedure 2017-41, procedures for issuing pre-approved plan opinion letters Revenue Procedure 2015-36, procedures for issuing pre-approved plan opinion and advisory letters Pre-approved retirement plans Types of pre-approved retirement plans Apply for an opinion or advisory letter Determination, Opinion and Advisory Letters
