S.C. Code Ann. § 59-4-80

The director shall solicit answers to applicable ruling requests from the Internal Revenue Service regarding the tax status of fees paid pursuant to a prepaid tuition contract to the contributor and to the designated beneficiary and from the Securities and Exchange Commission regarding the application of federal securities laws to the program. The director shall make the status of these requests known to the board. In accordance with applicable law or Internal Revenue Service ruling, the board shall structure the program in order to allow for federal tax deferral on contributions to the fund.