Post-PPA (Cycle 3) Restatement

What is a Post-PPA (Cycle 3) Restatement, and Does My Plan Need One?

This article discusses an upcoming deadline for certain 401(k) and Profit-Sharing plans, which may require updating your plan documents. This article will help you understand if your plan is affected and what next steps may be needed.

What is a Restatement?

Your 401(k) plan (the “Plan”) is created using a document pre-approved by the Internal Revenue Service (“IRS”). The benefit of using such a plan is that the accompanying IRS opinion letter ensures the basic form of the document meets the requirements of the Internal Revenue Code (“IRC”).  The IRS requires pre-approved documents to be updated on a six-year cycle to incorporate changes made to the governing tax laws and regulations. This is a normal and expected part of a plan document lifecycle, and we prepare updated plan documents as a standard part of our services. 

Click here for more information on the IRS’ pre-approved retirement plan program.

Does My Plan Need a Restatement?

The current restatement cycle, known as “Post-PPA” or “Cycle 3,” ends July 31, 2022, and you may need to take certain steps to update your plan document prior to that date.  We will reach out to you if there is action needed on your part to help us complete the restatement process. The following chart provides information on whether or not your plan may need to be restarted and, if so, the next steps in the process.

*The later of the original effective date of the plan or the effective date of the Plan’s restatement.

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