New IRS Guidance on Downsized DL Program – In Brief

On June 29, the Service released guidance covering a number of important changes in this area, including the “remedial amendment period” under Code section 401(b), plan amendment adoption deadlines, and issues for pre-approved plans.  Brief highlights of Revenue Procedure 2016-37, which generally replaces Rev. Proc. 2007-44 (which announced the “staggered 5-year filing system”), effective January 1, 2017, are provided in the attached alert.