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Frequently Asked Questions

for Defined Benefit and Cash Balance Plan Cycle 3 Restatements

What is the Cycle 3 restatement? 

The plan document will be rewritten to incorporate the appropriate law and regulation changes since the last restatement cycle. 


Is the restatement mandatory? 

Every six years, the IRS requires pre-approved plan documents to be restated for defined benefit and cash balance plans. The restatement must be done timely to maintain the tax-qualified and pre-approved status of the plan. 

What will be provided with the restated plan document? 

Our office will prepare and provide the following items:

  • Basic Plan Document 

  • Adoption Agreement

  • IRS Opinion Letter

  • Summary Plan Description

  • Board Resolution to adopt the Plan

  • Loan Policy (if applicable)

  • Participation Agreements (if applicable)

  • Beneficiary Designation Forms

  • Interim Amendments (if applicable)

What if my plan is new?

If your plan document was prepared before June 1, 2023, it is currently a PPA restatement document and must be restated regardless of the age of the Plan. 


What is the Cycle 3 restatement deadline? 

All defined benefit and cash balance plans using a pre-approved plan document must restate their plan documents by March 31, 2025, to maintain their tax-qualified and pre-approved status.


Why are we preparing the restatement now if the deadline is March 31, 2025?

Our goal is to design a plan that achieves your company’s retirement and tax goals. Early restatement allows time for discussion about improvements to the current plan design. Working on the restatement now, ensures the restatement is prepared by the compliance deadline and the plan design is optimized for your goals. 


What fee will be charged for the Cycle 3 restatement? 

Please refer to your Client Service Agreement for the New Plan Document Fee amount. This fee covers the time spent reviewing and preparing the restatement. As always, our fees can be paid out of plan assets. 


What if my plan is frozen or in the process of termination? 

The IRS provides no restatement exceptions for frozen or terminating plans. Terminating plans must be in full compliance with all applicable legislation upon plan termination.

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