Rev. Proc. 2016-37 describes a staggered remedial amendment system for

pre-approved plans that are qualified under § 401(a) of the Internal Revenue Code (Code). The revenue procedure provides separate six-year remedial amendment cycles for pre-approved defined benefit and pre-approved defined contribution plans.

Rev. Proc. 2017-41, 2017-29 I.R.B. 92, modifies the pre-approved letter program by combining the former master and prototype and volume submitter programs

into a single opinion letter program. Under this program, providers of pre-approved plans may continue to apply for new opinion letters once every six years. Rev. Proc. 2017-41 sets forth the procedures for providers to obtain opinion letters for qualified pre-approved plans submitted with respect to the third (and subsequent) sixyear remedial amendment cycles.

The on-cycle submission period for providers of pre-approved defined contribution plans to submit opinion letter requests under the third six-year remedial amendment cycle (set forth in Rev. Proc. 2016-37, and extended by Rev. Proc. 2017-41 and Rev. Proc. 2018-42, 2018‑36 I.R.B. 424) was October 2, 2017, through December 31, 2018. Rev. Proc. 2017-41 required pre-approved plan providers to restate their pre-approved defined contribution plans for the qualification requirements included on the 2017 Cumulative List and to apply for new opinion letters during this submission period.