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|Is This the End of Favorable Determination Letters? (PDF)|
Ferenczy Benefits Law Center LLP
Apr. 1, 2015
"It is being reported ... that the IRS is seriously considering whether to eliminate the favorable determination letter (FDL) program for all retirement plans. If the current thinking prevails, no FDLs will be available, except at the plan's inception and termination. This would mean that plans that are either individually designed (that is, not written in the form of a check-the-box plus boilerplate document that has been preapproved by the IRS) or for which the preapproved document has been significantly modified, will have no means after the initial year, or before termination, to have the IRS confirm that the language of the plan is acceptable."
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