"You may be able to avoid all future cash balance determination letter submissions -- but attention is needed for those plans you have been preparing to submit by January 31, 2014 to meet the Cycle C deadline ... For these plans (and all cash balance plans) if the employer and prototype sponsor/volume submitter practitioner sign IRS Form 8905 indicating an intention to adopt a pre-approved plan, then the deadline to submit the plan will be based on the 6-year cycle for pre-approved plans. We do not know what the deadline for adoption of pre-approved plans will be because the submission period for these was just extended to February 2, 2015. If the IRS takes 2 years to approve the plans, then we would expect the restatement period to begin no sooner than early 2017. If the plan is restated onto a pre-approved plan by the deadline and no modifications to the plan are made, then no determination letter submission is necessary (the IRS will not even accept the submission since the plan is already pre-approved)."

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