Schedule Q

[Scott]

Now that Schedule Q is optional under Announcement 2001-77, is there any real good reason for including it in a determination letter request? I don't see much benefit in getting a determination on the operational aspects of the plan, particularly as compared to the time and expense involved in preparing Schedule Q. A determination would be based on a one-time demonstration under Schedule Q, but a plan has to pass those tests every year, so how beneficial would that determination be? Am I missing something? Is there a significant downside to not submitting Schedule Q?

To the practitioners out there, on what side of this decision are most of your clients coming down?

[Scott]

Anyone have any thoughts?

[Guest Ronin]

The value of Schedule Q is greatly diminished. An IRS plan audit can discover operational errors which would totally invalidate any comfort a determination letter with Schedule Q language would provide.

My clients are opting not file the Schedule Q for that reason, as well as for the additional cost its preparation requires.

[Lynn Campbell]

For new plans where the User Fee is waived, isn't there some value in getting a letter that addresses the methodology used in cross-testing? What are others doing when they submit for GUST? I hate to ask a very basic question, but which Demo would be the one to use in this case?

[k man]

i submit a schedule q along with a demonstration 6 (general test) for the reason mentioned by lynn campbell. i think getting a letter on the methodology of the cross testing could be of some value in the future. particularly with no user fee for most plans it would seem to be a good move.