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Posted

I know we are in the process of doing the Cycle 3 restatements for all non-volume submitter DC Plans.  When are restatements due for any DC non-volume submitter plans due?

Thanks in advance!

Posted

Do not fully understand your question.

There are pre-approved plans (still referred to as volume submitter plans by some) which have a 6-year cycle. Pre-approved DCP are in the current cycle with a 7/31/2022 restatement due date.

Plan documents that are not on a pre-approved document (i.e., individually designed, or treated as such) are no longer on any cycle. They can get initial determination letters, DLs upon plan termination, and certain other special circumstances as IRS may allow. These plans are required to adopt interim amendments according to an IRS published list/schedule. If/when such amendments are due depends on the type of plan and what statutory requirements are lacking. Plans are not required to be restated until after 5 (I think) amendments and I don't think simple interim or administrative amendments count toward that.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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