Missed Restatement Deadline

We have pre-approved non-standardized documents.

All defined benefit plans had to be restated for Cycle 3 by March 31, 2025.

Even though about 90 plan sponsors did adopt the restated documents by March 31, 2025, we had 4 clients who did not.

Our understanding is that the restatements can be done through self-correction as long as they are adopted within two years of March 31, 2025. In addition, we believe the plans would need to adopt all amendments between the last restatement (PPA) and now (Cycle 3) to properly do this through self-correction. This as if the plan were an individual design.

Question: Is there a list somewhere of all the required amendments between the  PPA restatement and the current Cycle 3 restatement? If so, could you let us know?

Thank you.

Your best bet would be to ask your document software provider. 

There is probably also a "cumulative list" for DB plans that is published by the IRS.  Just google it.