The New Remedial Amendment Period (RAP)
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Individually Designed Plans (IDPs)
IDPs are on a 5-year staggered RAP, which is generally based on the last digit of the employer’s EIN. This cycle
applies to all plans which are not on pre-approved plans (volume submitter or prototype plans). ESOP and
cash balance defined benefit plans are always individually designed plans.
Last Digit of Employer’s EIN |
Plan Cycle |
Last Day of EGTRRA RAP Cycle |
Last Day of Next 5 Year EGTRRA RAP Cycle |
1 or 6 |
A |
Jan 31, 2007 |
Jan 31, 2012 |
| 2 or 7 |
B |
Jan 31, 2008 |
Jan 31, 2013 |
| 3 or 8 |
C |
Jan 31, 2009 |
Jan 31, 2014 |
| 4 or 9 |
D |
Jan 31, 2010 |
Jan 31, 2015 |
| 5 or 0 |
E |
Jan 31, 2011 |
Jan 31, 2016 |
Pre-Aproved Plans (Prototype and Volume Submitter Plans)
Pre-Approved plans are on a 6-year staggered RAP which is based on whether the employer has a Defined Benefit or Defined Contribution plan. Each plan type is on a separate cycle.
Timeline for Defined Contribution Plans:
Year 1 Submission of plans to IRS (Jan 31, 2006)
Year 2 and 3 IRS reviews and approves plans (2006 and 2007)
Year 4 and 5 Employers restate their plans (2008 and 2009)
Year 6 Rest for next 6 year cycle
Timeline for Defined Benefit Plans:
Year 1 Submission of plans to IRS (Jan 31, 2008)
Year 2 and 3 IRS reviews and approves plans (2008 and 2009)
Year 4 and 5 Employers restate their plans (2010 and 2011)
Year 6 Rest for next 6 year cycle