Plan Document Restatement

Preapproved defined contribution (DC) restatement: Preapproved DC plans (i.e., master, prototype, and volume submitter) are required to adopt an updated plan document every six years. Plan documents revised for the Pension Protection Act of 2006 (PPA) and subsequent law changes were submitted to the IRS before April 2, 2012. It is anticipated that employer adoption of the PPA document will begin May 1, 2014, and run for a two-year period until April 30, 2016.

Preapproved defined benefit (DB) restatement: These plans are also on a six-year restatement cycle, but they lag behind the DC plan cycle by two years. DB plan document drafters should have submitted plans to the IRS by January 31, 2014. Document approval is expected to follow in early 2016, and the PPA restatement period for employers to adopt updated preapproved DB plans will begin in May 2016.

Individually designed plans: These defined contribution and defined benefit plans are rewritten every five years. The five-year cycle is generally based on the last digit of the sponsor’s employer identification number (EIN). The current PPA restatement cycle C (for plan sponsors with an EIN ending in 3 or 8 and governmental plans) ended on January 31, 2014. Cycle D (for plan sponsors with an EIN ending in 4 or 9 and multiemployer plans) opened February 1, 2014, and ends January 31, 2015.

Preapproved 403(b) plans: For the first time ever, prototype and volume submitter 403(b) plan documents will be preapproved by the IRS. The expected timeline at this point is for document drafters to submit their plans for IRS review by April 30, 2014. If the timetable for preapproved 403(b) documents is similar to that of other preapproved documents, the review process would be completed sometime in 2016 and employers would have until sometime in 2018 to restate their existing documents.