Section 8.02 has been revised to provide that an adopting employer of a pre-approved M&P plan may file a Form 5307 for the second six-year remedial amendment cycle if the employer has added overriding language to the plan to reflect Code Sections 415 and 416 (26 U.S.C. §§ 415 and 416).

Section 12.01(3) has been modified to provide that a controlling member that makes modifications to a VS multiple employer plan in situations in which the modifications are not extensive may apply for a determination letter on Form 5300 in the two-year window described in Section 13.03 of the revenue procedure, regardless of whether an earlier favorable determination letter was issued. An adopting employer other than the controlling member may not apply for a determination letter.

Section 17.05 has been clarified to state that an adopting employer of a pre-approved plan must be otherwise eligible to submit a determination letter application in order to request a determination with respect to Code Section 414(n) (26 U.S.C. § 414(n)).

Section 30.11 has been revised to include the appropriate IRS unit to contact in a request for reconsideration of a user fee for opinion letter requests submitted under Rev. Proc. 2017–41.

Appendix A, .05 has been added to provide user fees for submissions for opinion letters on pre-approved plans under Rev. Proc. 2017–41.

The user fee schedule for VCP submissions in Appendix A, .09, has been revised to change the user fees to:

The user fee for Group Submissions remains unchanged.

The special fee waiver for terminating Orphan Plans remains unchanged.

All other reduced or alternative fees for VCP submissions previously set out in Appendix A, .09, no longer apply.

The user fee in Appendix A, .02, for opinion letters on prototype individual retirement accounts or annuities, SEPs, SIMPLE IRAs, SIMPLE IRA Plans, Roth IRAs and dual-purpose IRAs, has been increased from $1,000 to $2,500.

The user fee in Appendix A, .06(1)(c), for Form 5310 (Application for Determination for Terminating Plan), has been increased from $2,300 to $3,000.

Section 5.04 has been added to state that a request for a waiver of the minimum funding standard is submitted to the IRS Office of Associate Chief Counsel (TEGE), and a determination letter request is no longer available.

Sections 8.04, 11.02, and 11.03(1) are revised to delete provisions related to Cycle A determination letter submissions.

Section 11.05 has been changed to state that individually designed plans submitted for determination letters during 2018 must be restated for compliance with the 2016 Required Amendments List (as well as any applicable prior Cumulative List).

Sections 14.02 and 14.03 have been clarified to state that a determination letter applicant for a multiple employer plan must request a letter for the plan in the name of the controlling member.

Sections 22.03 and 23.08 have been changed to provide that a petitioner's request for relief under Code Section 7805(b) (26 U.S.C. § 7805(b)) must be submitted to the agent or specialist assigned to the case, in order to have exhausted administrative remedies; other procedures formerly contained in Rev. Proc. 2017-4 relating to Section 7805(b) requests have been deleted. Sections 29.04 and 29.10, regarding letter rulings, have been modified to provide that a request for Section 7805(b) relief to limit the retroactive effect of a revocation or modification should be submitted to the agent or specialist assigned to the case.

Section 23.05 has been modified to provide that the Director of Employee Plans has the authority to revoke or modify a determination letter.

Sections 24.01(2) and 26.02(2), which discuss changes in funding methods, and Section 31.01(1), which provides the appropriate address for letter ruling and opinion letter requests, have been updated to refer to Rev. Proc. 2017–57 (see Legal Update, IRS Revenue Procedures 2017-56 and 2017-57 Provide Guidance on Approval for Funding Method Changes for Defined Benefit Plans).

Section 24.01(9) has been modified to clarify the scope of a letter ruling on requests by the sponsor of a multiemployer plan for approval of an extension of an amortization period.

Sections 24.01(11) and 26.02(4), which relate to approval of the use of a substitute mortality table, and Section 31.01(1), which provides the appropriate address for letter ruling and opinion letter requests, have been updated to refer to Rev. Proc. 2017–55 (see Legal Update, IRS Final Regulations, Revenue Procedure 2017-55, and Notice 2017-60 Prescribe Mortality Tables for Defined Benefit Plans and Provide Related Guidance).

Section 25.01 is clarified to state that Employee Plans may decline to issue a letter ruling due to resource constraints.