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PART I — M&P PLANS

SECTION 15. AMENDMENTS ON

Internal Revenue Bulletin 2004-18 · 2026-10-03 edition · updated 2026-10-04 · United States

BEHALF OF ADOPTING EMPLOYERS

.01 Option to Permit Practitioner Amendment - A VS practitioner may amend its specimen plan and request a new advisory letter with respect to the amended plan. Ordinarily, the amendments will apply only to the plans of employers who adopt the plan after it has been amended and will not apply to plans of employers who adopted the plan prior to the amendment. However, a VS plan may, but is

which notifies the Service of its desire not to adopt such amendment will no longer participate as an M&P mass submitter plan but must apply for an opinion letter on its own behalf to retain its status as an M&P plan.

.05 Expeditious Processing Accorded M&P Mass Submitter Plans - All M&P mass submitter plans, including the adoption of approved M&P mass submitter plans by sponsors, will be accorded more expeditious processing than M&P plans submitted by non-mass submitters, to the extent administratively feasible.

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▸Contents — Internal Revenue Bulletin 2004-18

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