On September 23rd, the Internal Revenue Service (the ?IRS?) released Rev. Proc. 2011-44, which modifies the procedures for submitting a private letter ruling request that a plan constitutes a church plan. In connection with such ruling requests, Rev. Proc. 2011-44 adds a notice requirement and requires that an applicant represent whether the plan is a church plan that has opted out of ERISA coverage. The revenue procedure applies to both ruling requests received after September 26th, 2011 and ruling requests pending with the IRS as of September 26th, 2011.
