Cycle 3 Update for terminating DB Plan

[Barbara]

Hi, I have a Plan that expected to terminate and pay out benefits prior to June 30, 2023.  However, my document vendor (Ft William) doesn't yet have its Cycle 3 document ready, and says it won't have the doc until July sometime.

All the benefits have been calculated for a June distribution. This is a small, non-PBGC-covered Plan and we are not submitting to IRS.  Would you distribute anyway, and then update the document in July?  Or?  If we wait to distribute until after the docs are completed, we will have to recalculate everything.

 

Thanks in advance.

[CuseFan]

There is no requirement to restate but you need to make sure the plan language is up to date and any interim amendments after the last restatement have been timely adopted. If so, and they can adopt a CARES/SECURE amendment and a SECURE 2.0 amendment (which you may need to craft or tack language onto SECURE) and you should be OK. If a CBP with market return ICR, may want to double check document language is up to date/compliant as well.

[pensionreview]

Just to let you know that although ftwilliam does not have the cycle 3 restatement posted yet, it does have the SECURE 2.0 amendment available.