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Every six years, pre-approved retirement plan documents need to be restated to include IRS-mandated language that reflects new legal and regulatory requirements.
Besides pre-approved plans, an employer may also use an individually designed plan, which is a custom-built plan just for that employer. Individually designed plans are not on a restatement cycle. Each year, the IRS issues a list of required amendments that must be incorporated into the individual designed document.
The 2023 Cumulative List will assist providers applying to the Internal Revenue Service (IRS) for opinion letters for the fourth remedial amendment cycle for defined contribution qualified pre-approved plans (Cycle 4) under the IRSs pre-approved plan program. Cycle 4 began on February 1, 2023.
A restatement is a re-writing of the plan document. It incorporates all changes from any plan amendments that may have been adopted since the last time the document was re-written.
What is Cycle 3 Restatement? Cycle 3 is a document restatement event, part of a series that occurs every six years. The IRS requires all 401(k), profit sharing, and money purchase pension plans that are using pre-approved documents to be restated onto an updated document.
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From August 1, 2020 to July 31, 2022, all pre-approved 401(k) plans must be restated onto a Cycle 3 document. If youre a business owner, you dont want to miss the July 31, 2022 Cycle 3 restatement deadline because doing so can lead to steep IRS penalties up to plan disqualification.
Expiration dates on determination letters issued to individually designed plans prior to January 4, 2016, are no longer operative. Letters issued after that date do not contain an expiration date (see Revenue Procedure 2016-37, Section 13).

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