The IRS recently announced in Notice 2007-6 that it is, at long last, beginning to process determination letter applications for cash balance plans that have been subject to an IRS moratorium for many years. The Notice also provides some important transitional guidance regarding the new rules applicable to cash balance and other hybrid pension plans enacted as part of the Pension Protection Act of 2006 (PPA). The IRS indicates that it is working on regulations to address the new PPA rules for hybrid plans and solicits comments on a few specific topics. Attached is a summary of the guidance.
We are working to establish a coalition of plan sponsors to provide comments to the IRS on hybrid plans and we are looking for plan sponsors to join in as coalition members. Please let us know if you may be interested.