Lifting of Cash Balance Moratorium

[Scott]

Does an employer who filed for a determination letter for a converted cash balance plan that got stuck in the moratorium have to do anything now that the moratorium has been lifted, or does the employer just wait for the IRS to contact it to resume the process?

[Gary]

Why not contact the IRS DL department and ask?

[Guest puls]

If and when the IRS responds on the GUST filing, the IRS reviewer will request applicable compliance amendments necessary for the issuance of the GUST favorable determination letter. When the next IRS filing is made under the applicable Cycle (assuming not Cycle A), include the following: the GUST FDL, all discretionary amendments, and all compliance amendments not requested by the IRS in connection with the GUST FDL. Do not at this time voluntarily submit intervening amendments to the IRS reviewer identified on the IRS’s original acknowledgement letter, and do not submit ALL the intervening amendments when the IRS responds on the GUST filing (because they will not be addressed in the GUST letter).