User Fee for 2 Minimum Funding Waiver Requests

[Guest Matt123]

Sponsor of 2 defined benefit plans is assessing possible request of funding waivers for both plans. The material facts about business hardship are identical for each waiver request, and I'm sure the requests will be resolved in a single ruling (e.g., PLR 201229015). So, it makes sense for the IRS to charge just one user fee.

However, Rev Proc 2004-15 does not address the issue, Rev Proc 2014-8 does list a waiver (singular) at $14,500, and I would not necessarily describe the waivers a part of "only one transaction" as per 8.03 of 2014-8.

Any thoughts or experiences? Would like to be able to confidently describe relevant costs to sponsor before we start down this path.

Thanks in advance