Distinction between "opinion letter" and "determination letter"

[Guest Fishchick]

The 5307 form & instructions refer to both "opinion letter" and "determination letter." I have always thought these terms referred to the same document- the letter issued by the IRS to confirm the "qualified" status of a plan's written document.

Is there actually a distinction? Does anyone know why both terms are used?

[Lynn Campbell]

The Opinion Letter is an IRS approval letter to the Prototype Sponsor. The Determination Letter is from the IRS to the specific employer that used the prototype and requested a Determination Letter from the IRS. That is my understanding.

[Kirk Maldonado]

I believe that those terms (as well as many other related terms) are formally defined in the (revised) Revenue Procedure that the IRS issues at the start of the each year explaining how to get determination letters on tax-qualified retirement plans.