SECTION 2. BACKGROUND

.01 Rev. Proc. 2016–37, 2016–29 I.R.B. 136, provides that every preapproved plan has a regular, six-year remedial amendment cycle. Under Rev. Proc. 2016–37, the third six-year remedial amendment cycle for pre-approved defined contribution plans began on February 1, 2017, and ends on January 31, 2023. Rev. Proc. 2016–37 also provides that the 12-month on-cycle submission period for pre-approved defined contribution plans was scheduled to begin on August 1, 2017, and end on July 31, 2018.

.02 Rev. Proc. 2017–41 modified the pre-approved letter program by combining the master & prototype and volume submitter programs into a new Opinion Letter program. Under this program, providers of pre-approved plans may apply for new opinion letters once every six years. Rev. Proc. 2017–41 sets forth the procedures for obtaining opinion letters for qualified pre-approved plans submitted with respect to the third (and subsequent) six-year remedial amendment cycles. Rev. Proc. 2017–41 modified the on-cycle submission period for pre

September 4, 2018 424 Bulletin No. 2018–36

approved defined contribution plan providers to submit applications for opinion letters for the third six-year remedial amendment cycle to begin on October 2, 2017, and end on October 1, 2018.