What is the remedial-amendment date if the plan's sponsor will not apply for the IRS's determination?

[Peter Gulia]

An employer maintains an individually-designed plan. This plan is in cycle A. The plan received favorable determinations for the previous intervals of the cycle. The employer will not apply for the IRS's determination this winter.

For whatever could be the subject of a remedial amendment, what is the last day for the amendment to be executed?

Is it January 31, 2017?

Or is it (assuming all relevant tax and plan years are calendar year) December 31, 2016?