SECTION 4. TIMING PROVISIONS

RELATED TO REQUESTS FOR APPROVAL TO USE SUBSTITUTE MORTALITY TABLES

.01 In general . A request for approval to use substitute mortality tables generally must be submitted at least 7 months before the first day of the first plan year for which the substitute mortality tables are to apply. Thus, for example, if the first plan year to which substitute mortality tables are to apply is the plan year that begins January 1, 2026, then the deadline for submitting a request for approval to use substitute mortality tables is June 1, 2025.

.02 Incomplete requests . An incomplete request for approval to use substitute mortality tables will be denied unless the IRS and the applicant mutually agree to extend the 180-day period specified under § 430(h)(3)(C)(v)(II). If the request does not include substantially all of the applicable information specified in sections 5 through 11 of this revenue procedure, the IRS will ordinarily reject the request without considering the substance of the request (rather than agree to extend the 180-day period for review of the request) and refund the user fee.

.03 Request for delay for other plans. If other plans subject to § 430 maintained by the applicant (or members of the applicant’s controlled group) have credible mortality information and a request for approval to use substitute mortality tables will be made for those plans in one or more separate applications, the applicant must request that the 180-day review period be extended by 90 days. Upon receiving the request for extension of the review period,

2 It is recommended that an actuary who is able to answer technical questions about the construction of the substitute mortality tables be designated as an authorized representative. Not having an actuary available to discuss these tables with the IRS may cause a delay in the processing of a request for approval.

August 19, 2024 524 Bulletin No. 2024–34

.01 Information for plan for which approval to use substitute mortality tables is requested . The following plan information must be provided for the Plan (or for each plan within the Aggregated Group) for which approval to use substitute mortality tables is requested:

(1) Plan name; (2) Plan number; (3) Plan year (calendar year, or if a fiscal year, the first and last day of the plan year);

(4) Employer identification number; (5) Date of plan establishment; and (6) Copies of the actuarial valuation reports for each plan year that begins or ends during the Experience Study Period as defined in section 7.01 of this revenue procedure.

.02 Plans for which substitute mortality tables are not intended to be used. The following information must be provided for each plan that is subject to § 430 covering employees of the applicant, or a member of the applicant’s controlled group, for which substitute mortality tables are not intended to be used:

(1) Plan name; (2) Plan number; (3) Plan year (calendar year, or if a fiscal year, the first and last day of the plan year);

(4) Employer identification number;

except as provided in section 4.02 of this revenue procedure, the IRS will agree to that extension and give the applicant 90 days to submit those additional applications (which must be submitted no later than the deadline that applies to each such separate request under section 4.01 or 4.04 of this revenue procedure). The IRS will summarily reject the initial application if it does not include a request for a 90-day extension of the 180-day review period, or if any of the additional applications are not submitted within 90 days after the submission of the initial application (on the grounds that at least one plan with credible mortality information maintained by the applicant (or a member of the applicant’s controlled group) would not be using substitute mortality tables).

Example . Employer E maintains Plans A and B, each of which have credible mortality information. Plan A’s plan year is the calendar year and Plan B’s plan year runs from July 1 through June 30. Employer E submits a request for approval to use substitute mortality tables for Plan A for the 2026 plan year on May 31, 2025 (“Plan A Request”). To avoid denial of the Plan A Request on the grounds that substitute mortality tables would not be used for all plans with credible mortality information maintained by the applicant, Employer E requests that the 180-day review period for the Plan A Request be extended by 90 days to provide Employer E additional time to submit a separate request for approval to use substitute mortality tables for Plan B for the 2026 plan year. The IRS agrees to this extension in accordance with this section 4.03. The IRS will summarily reject the Plan A Request unless Employer E submits a separate request for approval to use substitute mortality tables for Plan B no later than August 29, 2025.

.04 Transition rule for submissions for plan years beginning in 2025 . Notwithstanding the generally applicable deadline in section 4.01 of this revenue procedure, a request for approval to use substitute mortality tables for a plan year beginning in 2025 will be considered timely if it is submitted on or before October 31, 2024, provided that the applicant requests a 90-day extension of the 180-day review period. Except as provided in section 4.02 of this revenue procedure, the IRS will agree to such a request.