We all forget about deadlines once in a while, but what happens when you miss the deadline for your PPA Restatement?
April 30, 2016, was the deadline for employers using pre-approved retirement plan documents to adopt, via a PPA Restatement, an updated version of their 401(k), profit-sharing or other defined contribution retirement plans.
Why Retirement Plan Documents Must Be Restated
Retirement plan documents, including 401(k), Profit Share and Defined Benefit Plan must be revised when the law changes.
Every 5 to 6 years, the IRS requires all retirement plans to amend and restate retirement plan documents, regardless of document amendments or restatements during that same time period. The most recent IRS mandated retirement plan document restatement is referred to as the PPA Restatement. An out-of-date plan document is the first item the IRS lists in its 401(k) Plan Fix-It Guide of common plan mistakes.
Not Sure if You Completed the PPA Restatement?
LRS has you covered. We will review the retirement plan legal documents you have readily available and work with your service providers to determine if you adopted new and revised retirement plan legal documents by the IRS deadline of April 30, 2016. Keeping the plan document current is part of ongoing plan administration.
Think You Missed the PPA Restatement Deadline?
Not a problem. We can amend and restate your retirement plan legal documents to meet the PPA Restatement requirements. We will take you and your retirement plan through the IRS approved correction program, and our consulting and correction services cover what that involves.
Helpful Resources
- IRS Announcement 2020-07 — the six-year remedial amendment cycle for pre-approved defined contribution plans, including the Cycle 3 window that ran from August 1, 2020 to July 31, 2022.
- IRS, 401(k) Plan Fix-It Guide — how to find, fix and avoid an out-of-date plan document and the other common failures.
- IRS, Voluntary Correction Program — correcting a missed restatement with IRS approval before an audit.
- IRS, Correcting plan errors — the full set of correction programs available to plan sponsors.
Keeping a plan document current is one obligation. Having a plan at all is becoming another: a growing number of states now require employers above a certain size to offer a qualifying retirement plan or enroll their employees in a state-facilitated program.
- Which states have mandatory retirement plans — who is affected and what triggers the requirement.
- State retirement mandate map — the current position and deadline for every state.
Do You Have More Burning Questions?
Take a look at our blog for more industry insights and information, or contact our team directly.
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