"[Groom Law Group submitted letters] recommending consideration of the following plans as applicants for updated determination letters: [1] Plans with a cash balance or similar benefit formula whose last determination letter was before the effective date of the final IRS hybrid plan regulations. [2] Plans that address income replacement and inflationary pressures through adoption of a variable annuity feature. [3] Traditional pension plans that convert to a cash balance-type formula. [4] Plans that undergo major changes that otherwise make certain compliance testing unnecessary -- such as safe harbor 401(k) plans. [5] Plan changes accompanying significant workforce adjustments, such as downsizings or corporate separations. [6] Corrective plan amendments submitted as part of an EPCRS submission. [7] Governmental plans where there has been a significant change in the governing state or local law."

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