Should governmental plans file for determination letters this year?

[Guest Patti]

I am just curious whether most governmental plans are filing for determination letters this year,(presumably for applicable GUST requirements or because they have never filed before)?

[Carol V. Calhoun]

A lot of governmental plans never file for determination letters. In most instances, this is because they are imposed by statute, and there is doubt whether changes to the statute required by IRS as a condition to qualification can be adopted within 90 days after issuance of a determination letter (as is required in order to have any favorable determination given effect). However, those plans which have previously routinely received determination letters (in general, those which do have the ability to adopt the necessary amendments in a timely manner) do appear to be filing again this year.