Pension Protection Act Blog

The IRS announced they will stop accepting applications for opinion/advisory letters for prototypes and volume submitter defined benefit plans not restated for EGTRRA and the 2006 Cumulative List as of September 7, 2007. In Announcement 2007-61, the IRS provides three final time frames for GUST.

Before Feb. 1, 2007 - applications for opinion/advisory letters for defined benefit plans filed before February 1, 2007, will be reviewed for GUST. They will not be reviewed for EGTRRA or subsequent law changes.

Between Feb. 1, 2007 and before Sept. 7, 2007 - applications will only be reviewed for GUST unless the plan was restated for EGTRRA and the 2006 Cumulative List.

On or after Sept. 7, 2007 - applications will only be processed if the plan included in the application has been restated for EGTRRA and the 2006 Cumulative List. The IRS says that it will return applications filed on or after Sept. 7, 2007, which contain plans not restated for EGTRRA and the 2006 Cumulative List.

With this announcement, the IRS officially ends the GUST era for prototype and volume submitter plans as the IRS closed the GUST program for defined contribution plans last year.

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