Retirement Plan Audits

[Opinion] Testimony on Behalf of ASPPA and NTSAA Before DOL Advisory Council on Employee Welfare and Pension Benefit Plans on the Subject of Pension Plan Auditing,'Limited Scope'Audits and Financial Reporting Models
4 pages. (American Society of Pension Professionals&Actuaries)

[Opinion] Statement on Behalf of Profit Sharing/401k Council of America before Working Group on Employee Benefit Plan Auditing and Financial Financial Reporting Models
2 pages. (Profit Sharing / 401k Council of America)

[Guidance Overview] Options for Obtaining a Determination Letter for Your Prototype Plan
Excerpt:"Sponsors of prototype plans had their profit sharing and 401(k) plan documents approved by the IRS and received Opinion Letters from the IRS on or before April 30, 2008. Employers can rely upon the Opinion Letters and do not need to obtain individual determination letters."(Employee Benefit News; free registration required)

U.S. Oversight of UAL Pension Audits Questioned
Excerpt:"The Pension Benefit Guaranty Corp . . . inspector general said in a letter to a congressional committee that the agency acknowledges some shortcomings in validating the value of the plans but does not believe they will require any changes to benefits."(Reuters)

IRS Retirement Plan Determination Letter Fees to Increase in 2011
Excerpt:"IRS user fees for most retirement plan determination letter applications will increase on Feb.1, 2011, just after the close of EGTRRA Cycle E."(Mercer LLC)

IRS Advisory Committee Recommends Changes to Determination Letter Process
Excerpt:"IRS Director of EP Rulings and Agreements Andy Zuckerman said that EP wants to improve the interim amendment process, will expand its education and outreach for government plans, and is implementing changes to the processing of 403(b) plans, among other changes."(Wolters Kluwer)

Fringe Benefits a'Key Area'of Upcoming IRS Audits
Excerpt:"The IRS is on a mission to learn what issues are hiding in employers'records; thus, the [employment tax national research program] audits will prove to be more invasive than they would be if auditors had a specific target."(Thompson Publishing Group Inc.)

[Guidance Overview] Employee Plans Subcommittee of IRS???s Advisory Committee on Tax Exempt and Government Entities Publishes History of Determination Letter Process
Excerpt:"The report also contained recommendations for streamlining the determination letter process, improving customer service, and a review of the fee structure for certain nonamender failures that are corrected using the Voluntary Correction Program provisions provided under ECPRS."(McKay Hochman Co.)

The SPARK Institute Reviews the IRS 401(k) Compliance Check Project (PDF)
4 pages. Excerpt:"The SPARK Institute, working with its members, has reviewed the questionnaire and is concerned that many of the questions and the available responses could have significant implications for plan sponsors and result in an audit or enforcement action. Accordingly, therefore, it is critical that plan sponsors fully understand the implications of the questionnaire and the potential consequences of their responses. Plan sponsors should be sure that their responses are complete and accurate to avoid triggering a costly enforcement action."(The SPARK Institute)

Advisory Committee on Tax Exempt and Government Entities'June 9, 2010, Report with Six Recommendations (PDF)
405 pages. Excerpt:"[Recommendations include:] Employee Plans: Analysis and Recommendations Regarding the IRS's Determination Letter Program; Exempt Organizations: Getting It Right - An Online Guide to Setting Executive Compensation for Charities."(U.S. Internal Revenue Service, Advisory Committee on Tax Exempt and Government Entities)

Investment Policy Statement Pitfalls
Excerpt:"A good policy not only keeps the overall investment plan well grounded, but it also provides a road map to develop specific asset allocation strategies and detailed investment guidelines."(San Francisco Chronicle)

The 401(k) Plan Compliance Check
Excerpt:"Observation: We anticipate that the IRS will use the compliance questionnaire to develop a more focused examination program in the future. To better position themselves for enhanced audit activity, companies whose 401(k) plans have not been selected to complete the compliance questionnaire may want to perform their own compliance check, perhaps using the questionnaire as a guide, and correct any identified errors through the IRS voluntary correction programs."(PricewaterhouseCoopers LLP)

[Guidance Overview] Required 2010 Tax-Qualified Plan Amendments and January 2011 IRS Determination Letter Filing Deadline (PDF)
3 pages. Excerpt:"Plan sponsors should review their tax-qualified plans annually to ensure that all necessary amendments are adopted on a timely basis. This can be challenging because the timing rules for plan amendments have become quite complex due to the interplay between the rules sometimes contained in new laws and the rules imposed by the Internal Revenue Service. It is important to meet these rules as IRS determination letter reviewers thoroughly review plan amendments . . . ."(Groom Law Group)

[Official Guidance] Text of the IRS Employee Plans FY 2010 Work Plan (PDF)
Excerpt:"The FY 2010 EP Work Plan includes seven operating priorities which address EP's mission in FY 2010 of protecting retirement plan assets and the benefits of plan participants. The integral focus of the EP Work Plan is to foster and promote plan sponsors compliance with the applicableInternal Revenue Code provisions. While the Determination, Voluntary Compliance and Technical Activities programs are designed to assist plan sponsors compliance with the Internal Revenue Code (IRC), EP Examinations and the EP Compliance Units ensure compliance through their enforcement actions."(U.S. Internal Revenue Service)

IRS Retirement News for Employers, Spring 2010 (PDF)
14 pages. This edition includes articles on the 401(k) Questionnaire; Upcoming 5500 Filing Deadline; Fixing Common Plan Mistakes: Improper Forfeiture Suspense Accounts; IRS Employee Plans Videos - Helping Small Business Owners and Employees; Nationwide Tax Forums!; New Profit Sharing Publication; Who Can Represent a Plan Sponsor During an Employee Plans Examination?; IRS Summer Phone Forums; Employee Plans Published Guidance. (U.S. Internal Revenue Service)

IRS Asking 401(k) Plan Sponsors to Answer Questionnaire
Excerpt:"The IRS announced last week that it will be looking at 1,200 401(k) plans by way of a plan compliance questionnaire. Letters from the IRS are expected to go out at the end of May. . . . Answering the questionnaire is'technically voluntary,'but an IRS spokesperson made it clear that they want the information."(Fisher&Phillips LLP)

[Guidance Overview] The 401k Audit: How to Stay Out of the DOL Spotlight (PDF)
10 slides. Excerpt:"Best practices to reduce risks. Validate the payroll process: Verify the payroll department: Understands the definition of compensation; Use forfeitures balances and bring the balance to zero at least once a year; Verify employee contributions are remitted ASAP (i.e. on the withholding date)."(Salmon Sims Thomas)

[Opinion] ASPPA Comments on Extension of IRS Determination Letter Program for Pre-approved Defined Contribution Plans
4 pages. Excerpt:"ASPPA recommends that the IRS continue to allow plans to apply for determination letters using Form 5307 beyond April 30, 2010, in the circumstances described herein. This is not a request to extend the time to restate pre-approved defined contribution plans to comply with EGTRRA."(American Society of Pension Professionals&Actuaries)

[Guidance Overview] IRS Priority List Indicates Increase in International Employee Benefits Compliance Efforts (PDF)
4 pages. Excerpt:"First are issues surrounding Puerto Rico plans and'dual status'plans. In addition to the US tax treatment of distributions (see, e.g., Rev. Proc. 2004-37) and deductions for contributions, the IRS has been working with the Hacienda in Puerto Rico to train plan auditors . . . . Another area appears to be the valuation of foreign plan investments and disclosures."(Groom Law Group)

EBSA Unified Agenda Entries from the DOL Spring 2010 Semi-Annual Agenda, Issued April 26, 2010
The target page provides links to three agenda items: Improved Fee Disclosure for Welfare Plans [EBSA Proposed Rule Stage - 1210-AB37]; Claims Procedure Regulation [EBSA Proposed Rule Stage - 1210-AB39]; and, QDIA - Target Date Fund Disclosure [EBSA Proposed Rule Stage - 1210-AB38] with a fact sheet for each. (U.S. Employee Benefits Security Administration)

.s. Department of Labor Agency Heads to Host Live Web Chats on Regulatory Agendas on April 26, 27 and 28
Today, Monday, April 26, the Employee Benefits Security Administration Web chat will be at 2 to 3 p.m. EDT. (U.S. Employee Benefits Security Administration)

[Opinion] American Benefits Council Letter to IRS Regarding Enhancements to EPCRS (PDF)
Excerpt:"The Council strongly supports the Employee Plans Compliance Resolution System ('EPCRS'). EPCRS has been a tremendous success. It recognizes that the benefit plan rules are complicated and that occasional compliance failures are inevitable. EPCRS encourages employers to timelyidentify errors and provides methods of correction at a reasonable cost. . . . It is important that EPCRS evolves just as retirement plans evolve. To this end, we are writing to suggest further improvements to the program."(American Benefits Council)

DOL's Website of Form 5500 and Other Enforcement Data
Excerpt:"EBIA Comment: The website produces EBSA reports that can be downloaded into a spreadsheet with headings for plan name, plan administrator, state and zip code, plan EIN, plan number and year, case type (deficient, late, or non-filer), closing reason (e.g., closed after correspondence or closed after referral to administrative law judge), closing date, and penalty amount."(Employee Benefits Institute of America)

IRS Officials Provide Status Updates and Reminders for Plan Determination Letters
Excerpt:"At a March 31, 2010 teleconference, IRS Employee Plans Rulings&Agreements Director Andrew Zuckerman set out several upcoming goals of the IRS determination letter program and Employee Plans Determinations Manager Vickie Surguy reminded practitioners of upcoming deadlines regarding determination letter requests."(Wolters Kluwer)

No More Opinion Letters from DOL's Wage and Hour Division
Excerpt:"The Department of Labor's Wage and Hour Division has announced it will no longer publish opinion letters to provide fact-specific guidance to employers and employees. According to an article by James M. Coleman and Maureen R. Knight, attorneys in the Fairfax, Virginia, office of Constangy, Brooks&Smith LLP, in the future requests for opinion letters will be responded to by providing references to statutes, regulations, interpretations and cases that are relevant to the specific request, but without an analysis of the specific facts presented, called'administrator's interpretations.'"(PLANSPONSOR.com)

IRS to Issue Opinion and Advisory Letters for Pre-Approved DB Plans Restated for EGTRRA and Other Changes
Excerpt:"The IRS has announced that it will soon issue opinion and advisory letters for pre-approved (i.e., master and prototype (M&P) and volume submitter (VS)) defined benefit plans that were restated for the Economic Growth and Tax Relief Reconciliation Act (EGTRRA; P.L. 107-16) and other changes in plan qualification requirements listed in Notice 2007-3 ('the 2006 Cumulative List') and that were filed with the IRS."(Wolters Kluwer)

EBSA Enforcement Results Data Posted to the Web
Excerpt:"The Employee Benefits Security Administration (EBSA) is one of a number of Department of Labor (DoL) agencies participating in a new Web site aimed at making a variety of enforcement data publicly available."(PLANSPONSOR.com)

Adoption and Filing Deadlines for Preapproved Defined Benefit Plans Announced
Excerpt:"IRS has set adoption and filing deadlines for master-and-prototype and volume-submitter defined benefit (DB) plans (Announcement 2010-20). Sponsors of preapproved DB plans soon will receive opinion and advisory letters on their plan documents as restated for EGTRRA and other changes. Adopting employers must sign the preapproved DB plan documents during the roughly two-year period ending April 30, 2012, and may opt to apply for individual determination letters starting May 1, 2010. For preapproved defined contribution plans, employers face an April 30, 2010, adoption deadline."(Mercer LLC)

[Official Guidance] Handout from the Phone Forum: IRS Retirement Plans Determination Letter Program (PDF)
54 pages. The Retirement Plans Determination Letter Program phone forum discussed the progress of the new DL program and tips on completing the new Form 5307. (U.S. Internal Revenue Service)

PowerPoint Presentation: Avoiding Issues in Plan Audits
30 slides. A presentation by Jason Loden, Partner, Thompson&Knight LLP, on avoiding issues in IRS, DOL and other plan audits. (Thompson&Knight LLP)

IRS Will Open EGTRRA Determination Letter Program
Excerpt:"The IRS has announced it will soon issue opinion and advisory letters for pre-approved defined benefit plans that have been restated for Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) and the guidance on the 2006 Cumulative List."(PLANSPONSOR.com)

IRS Offers Determination Letter Program Insights on March 31
Excerpt:"The Internal Revenue Service (IRS) is conducting an audio forum on its new determination letter program for qualified plans. According to an announcement, Andrew Zuckerman, Director of Employee Plans Rulings and Agreements, will be joined by Vickie Surguy, Manager, EP Determinations, to discuss: the status of the new determination letter program, the types of'reliance'available to preapproved plans, with or without a determination letter, tips on completing the new Form 5307, along with ways to avoid common mistakes to make the process go more smoothly."(PLANSPONSOR.com)

Fewer Defined Benefit Plans, More 401(k) Plans, But Only a Net Gain of 34 New Plans in Fiscal 2009
Excerpt:"The Internal Revenue Service issued 17,847 determination letters to qualified retirement plans during the fiscal year ending Sept. 30, 2009, according to statistics in the IRS's Data Book, 2009. There was a net gain of 34 new retirement plans during the year (3,329 initial qualification letters versus 3,295 plan terminations). The IRS reported that 11,223 plans received approval letters for plan amendments."(Wolters Kluwer)

[Guidance Overview] IRS Reminder to Employers of April 30 Filing Deadline for Adopting Pre-Approved Plans
Excerpt:"The IRS has reminded employers entitled to use the pre-approved plan six-year cycle of the April 30, 2010 deadline to adopt the final approved version of the defined contribution pre-approved plan and submit applications for determination letters, if applicable."(Wolters Kluwer)

ERISA Advisory Council Meeting Scheduled for March 22, 2010
Excerpt:"The U.S. Department of Labor (DOL) announced the first 2010 meeting of the Advisory Council on Employee Welfare and Pension Benefit Plans (ERISA Advisory Council). The purpose of the meeting is to introduce the council chair and vice chair, provide updates on DOL Employee Benefits Security Administration activities and determine topics for the advisory council to address in 2010."(International Foundation of Employee Benefit Plans)

DOL Participating in Open Government Initiative; Accepting Comments on Their Services Until March 19
Excerpt:"The Department of Labor (DOL), along with other agencies across the federal government, is gathering ideas from the public online to comply with the White House Open Government Initiative to increase transparency, participation, and collaboration. The DOL has developed an Open Government Plan. To learn more about this initiative, see their Web site at www.dol.gov/open. The DOL is asking for the public's input about how they can improve their services."(International Foundation of Employee Benefit Plans)

IRS Retirement Plans Determination Letter Program Forum: March 31, 2010, via Phone
Excerpt:"Andrew Zuckerman, Director of Employee Plans Rulings and Agreements, will be joined by Vickie Surguy, Manager, EP Determinations, to discuss the status of the new determination letter program, the types of'reliance'available to preapproved plans, with or without a determination letter, tips on completing the new Form 5307, along with ways to avoid common mistakes to make the process go more smoothly."(U.S. Internal Revenue Service)

[Guidance Overview] Courts and IRS Weigh in on Mandatory Conversion of Terminated Participants'ESOP Accounts (PDF)
5 pages. Excerpt:"Plan sponsors of employee stock ownership plans (ESOPs) that have been submitted for a favorable determination letter know that the IRS is carefully reviewing plan provisions that provide for themandatory conversion of a terminated participant's ESOP account balance from employer securities to cash. Recent case law and IRS analysis provide a hopeful resolution that should allow ESOPs to retain this right, providing that newly articulated requirements are met."(Morgan, Lewis&Bockius LLP)

[Guidance Overview] April 30 EGTRRA Restatement Deadline Approaching for Defined Contribution Plan Documents (PDF)
3 pages. Excerpt:"Plan sponsors are reminded that April 30, 2010 is the deadline for adopting preapproved master and prototype (M&P) and volume submitter (VS) defined contribution plan documents that have been updated to comply with the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) and other changes in plan qualification requirements. Additionally, plan sponsors that desire to file their M&P and VS defined contribution plans for determination letters from the IRS must submit the request to the IRS on or before April 30, 2010."(Morgan, Lewis&Bockius LLP)

Reish&Reicher ERISA Controversy Report, March 2010 (PDF)
Articles include'Issues In Terminating Defined Benefit Plans','IRS Audits and Bonding for 401(k) Plans', and'The Litigation Benefits of a Self-FundedDisability Plan."(Reish&Reicher)

[Opinion] American Society of Pension Professionals&Actuaries'Letter Suggestions for Improvements to EPCRS
9 pages. Excerpt:"On February 18, 2010, ASPPA filed comments with the IRS suggesting ways in which the Employee Plans Compliance Resolution System ('EPCRS') could be improved. The letter was in response to a request for comments found in Revenue Procedure 2008-50."(American Society of Pension Professionals&Actuaries)

Is a Department of Labor Investigation in the Future of Your Plan? (PDF)
3 pages. Excerpt:"Recent events suggest that the number of DOL plan investigations and penalties will increase. The first is the recession. Whenever the stock market retreats and plan accounts go down, participantscontact the DOL to complain about their plans. A sizable percentage of DOL plan investigations begin based upon these phone calls."(Benefit Consultants Group)

ITS Opinion Letter Program for 403(b) Plans Set to Launch April 1
Excerpt:"At the annual Washington Non-Profit Legal&Tax Conference, Jason Levine, an IRS employee plans tax law specialist, said the program launch will coincide with a redesign of the agency's Web site information on 403(b) plans, according to BNA. Levine said the opinion letter program for 403(b) prototype plans will review only plan documents and adoption agreements, and if a plan document and its investment documents contain conflicting provisions, the plan document'will control.'"(PLANSPONSOR.com)

Senate Bill Stirs Retirement Plan Lobby: Trade Groups Want to Avert Addition of Third Regulator to Mix of Overseers
Excerpt:"As the Senate convenes this week to debate its version of a financial services reform bill, financial advisers and service providers working with retirement plans are trying to avert the possibility of coming under greater regulation by an existing or new government agency."(Investment News; free registration required)

IRS Compliance Initiative Focuses on 401(k) Plans
Excerpt:"Starting in March, a random sample of 401(k) plan sponsors will receive IRS questionnaires as part of a new initiative to gauge the'health'of these plans. The Employee Plans Compliance Unit (EPCU) is launching this program to'better understand compliance behaviors'and to determine the extent to which employers are correcting errors and using IRS-developed compliance tools."(Mercer LLC)

[Guidance Overview] Deadline Approaching for EGTRRA Restatement and IRS Determination Letter Filings for Prototype and Volume Submitter Plans
Excerpt:"The deadline for restating plans for EGTRRA and requesting a determination letter on such restatements is April 30, 2010. Employers who have not been contacted by their document providers to prepare a restatement of a prototype or volume submitter defined contribution plan should immediately contact the provider to have the plan restated for EGTRRA."(Perkins Coie LLP)

[Guidance Overview] IRS Employee Plans Exam Projects
Excerpt:"EP Examination Projects - Learn, Educate, Self-Correct and Enforce (LESE) Projects: These examinations are small and quick projects wherein returns selected for audit contain issues of interest in a particular segment. Form 5500 returns selected for LESE examinations are based on'judgment sampling.'These examinations do not involve selection of returns through statistical sampling methods, but involve the random selection of approximately 50 examinations. The goal of this program is to apply the focused examination concept to LESE examinations to test and measure plans'compliance levels."(McKay Hochman Co.)

[Guidance Overview] Determining If Your 403(b) Plans Are Subject to the Audit Requirement (PDF)
2 pages. Excerpt:"Large ERISA plans will be required to file audited financial statements beginning with the 2009 Form 5500 filing. A large plan is an ERISA plan with more than 100 participants at the beginning of the plan year. Small ERISA plans are generally exempt from the audit requirements provided the requirements of the DOL's small plan audit waiver are satisfied. A small plan is an ERISA plan with less than 100 participants at the beginning of the plan year."(ERISA diagnostics, Inc.)

[Guidance Overview] Cycle D Submission Period Ends on February 1, 2010
Excerpt:"Because January 31, 2010 is a Sunday, the deadline for Cycle D determination letter applications is extended to Monday, February 1, 2010, the IRS has advised. An individually designed plan is in Cycle D if the plan is a multiemployer plan or the plan is a single-employer plan, and the last digit of the plan sponsor's employer identification number is 4 or 9."(Wolters Kluwer)

Procedures Updated for Furnishing of Technical Advice by Employee Plans or Exempt Organizations Technical Offices
Excerpt:"[IRS Revenue Procedure 2010-5] also explains a taxpayer's rights when an EP or EO Examinations Area manager, an EP or EO Determinations manager, or an Appeals Area Director requests technical advice regarding a tax matter. The procedure may also be used where another Operating Division of the IRS has audit jurisdiction while EP Technical has interpretive jurisdiction. The procedures are effective January 4, 2010."(Wolters Kluwer)

[Guidance Overview] IRS's 2010 Schedule of Employee Plan User Fees
Excerpt:"The IRS has updated its user fee schedule in IRS Revenue Procedure. 2010-8, effective January 4, 2010, for requests for various types of employee plan letter rulings and determination letters, and other matters under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division."(Wolters Kluwer)

[Official Guidance] New Submission Procedures for Individually Designed Plans: 5-Year Remedial Amendment Cycle for Individually Designed Plans Chart
Excerpt:"Because January 31,2010 is a Sunday, the deadline for Cycle D determination letter applications is extended to Monday, February 1, 2010. Note that some Cycle D plans with fiscal year plan years may make a one-time election to file in Cycle E under a special rule in section IV of the 2008 Cumulative List (Notice 2008-108). Since February 1, 2010 is also the first day of the Cycle E submission period, to avoid confusion as to whether a particular plan is filing under Cycle D or Cycle E, the IRS requests that a plan sponsor of a Cycle D plan filing on February 1, 2010, who is electing to file under Cycle E under this special rule, note this on a cover letter or on the application."(U.S. Internal Revenue Service)

[Guidance Overview] Updated IRS Procedures for Issuing Letter Rulings, Determination Letters, and Other Employee Plan Guidance
Excerpt:"EBIA Comment: These revenue procedures are required reading for anyone seeking plan-specific guidance from the IRS. Those new to employee benefits will welcome the procedures'practical tools, including sample formats and checklists for letter ruling requests, definitions of basic terms, user fee schedules, and descriptions of how the 2010 procedures differ from their 2009 counterparts."(Employee Benefits Institute of America)

[Official Guidance] Cycle D Filing Deadline Extended to February 1
Excerpt:"As January 31 falls on Sunday, the Cycle D determination letter application deadline is extended to February 1, 2010. The 2008 Cumulative list allows some fiscal plan year Cycle D plans a one-time election to file in Cycle E. The IRS requests that a Cycle D plan electing to file under Cycle E on February 1, note this on the application."(U.S. Internal Revenue Service)

Results from Two IRS Compliance Projects Highlight Common 401(k) and Small Plan Errors
Excerpt:"EBIA Comment: These examination projects reflect and reinforce the IRS's concern about small plan compliance. As the IRS summary of Project #1 observed:'The results revealed the expected -- Various issues arise with more frequency in smaller plans due to less oversight and weaker internal controls.'"(Employee Benefits Institute of America)

[Guidance Overview] New IRS Document Updates Determination Letter Procedures
Excerpt:"The Internal Revenue Service (IRS) has updated its procedures for requesting determination letters on the qualified status of pension, profit-sharing, stock bonus, annuity, and employee stock ownership plans."(PLANSPONSOR.com)

DOL Investigations of Retirement Plans May Be Increasing
Excerpt:"The 5500 red flags include diversification ratios, low rate of return on contributions, untimely contributions, insufficient rents paid for property or insufficient interest paid on loans, loan or lease defaults, plans with a large percentage of assets in real estate, assets such as limited partnerships, high expense ratios, high administrative expenses, high attorney or accountant fees, noncash contributions, and non-exempt transactions with a party in interest."(PLANSPONSOR.com)

[Guidance Overview] IRS List of Qualification Requirements for Retirement Plans
Excerpt:"In Notice 2009-98, the Internal Revenue Service sets forth the 2009 Cumulative List of Changes in Plan Qualification Requirements described in Sec. 4 of Rev. Proc. 2007-44, C.B. 2007-2, 54. The 2009 Cumulative List is to be used primarily by sponsors of individually designed retirement plans that are in Cycle E."(Wolters Kluwer)

IRS Audits Find Fiduciary Bond Inadequacies in Small DC Plans
Excerpt:"Inadequate bonding of plan fiduciaries and others who handle plan funds was the most common error identified in recent IRS audits of approximately 50 defined contribution plans with assets between $100,000 and $250,000."(Mercer LLC)

[Guidance Overview] IRS's 2009 Cumulative List of Changes for Cycle E Plans and Extension of Diversification Amendment Deadline
Excerpt:"EBIA Comment: All sponsors of Cycle E plans (and other plans filing in Cycle E) and their advisors should carefully review the 2009 Cumulative List to ensure that their submissions address the issues the IRS has specifically identified for review in the determination letter process. Of course, to be qualified, plans must comply with all relevant qualification requirements, even those that are not on the list."(Employee Benefits Institute of America)