When to file for determination letter

[DMcGovern]

I hope this is under the correct topic!

New cash balance plan on an individually designed document. The sponsor's EIN ends in a 3, so they would be in cycle C. Rev. Proc. 2007-44 provides for a new individually designed plan to file for a determination letter in the current cycle if their regular cycle ends at least two years after the end of the current cycle. This type of filing is given the same priority as on-cycle filers.

This Rev Proc also provides, "the initial remedial amendment period for a new plan is extended to the end of the applicable remedial amendment cycle in which the remedial amendment period would otherwise end."

With this in mind, I'm not sure I am seeing the advantage to the client for filing now, rather than waiting to file in their regular assigned cycle? If we did file now, they would have to file again (if they chose to) in the next regular cycle anyway, right?