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New IRS Revenue Procedure for Qualified Retirement Plan Document Determination Letters (PDF)
Ferenczy Benefits Law Center LLP 
[Guidance Overview] July 12, 2016
"An interesting -- and likely unintended -- side effect of these rules is that restating an [individually designed plan (IDP)] onto another individually designed document, such as when a plan sponsor changes benefits counsel, will come with considerable risk. While the existing plan document will be able to rely in large part on its existing [favorable determination letter (FDL)], whenever it was issued, the new document will not be able to do so and a new FDL will be unavailable."
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