SECTION 23. SECOND ON-CYCLE

SUBMISSION PERIOD (POST–EGTRRA) FOR PRE- APPROVED DB PLANS

The second on-cycle submission period (post-EGTRRA) began on February 1, 2013, and was scheduled to end on January 31, 2014, for applications for

Bulletin No. 2015–27 41 July 6, 2015

opinion and advisory letters for defined benefit plans that take into account the changes identified on the 2012 Cumulative List. Anns. 2014–4 and 2014–41 extended the deadline to submit on-cycle applications for opinion and advisory letters for such defined benefit plans to June 30, 2015. Pursuant to this revenue procedure, the deadline to submit on-cycle applications for opinion and advisory letters for such defined benefit plans is extended to October 30, 2015. Plans submitted in accordance with this extension will continue to be reviewed based on the 2012 Cumulative List. However, a plan must comply in operation with all relevant qualification requirements, not just those on the 2012 Cumulative List. In addition, if a plan has not been previously reviewed for items on earlier cumulative lists, the plan must still take those items into account. For example, pre-approved defined benefit plans have not yet been reviewed for items on the 2007 Cumulative List, so those items have been retained on the 2012 Cumulative List. The IRS will announce the deadline for timely adoption by employers when the review of the preapproved documents is close to being completed.