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2022 Deadline Nears: Now is the Perfect Time to Review Your Retirement Plan Design

For the millions of business owners that offer a workplace retirement plan, the COVID-19 pandemic created many financial difficulties.


However, as the economic climate improves, there is an opportunity for employers to refresh their company’s retirement plan. With an important plan document restatement deadline happening in 2022, there’s never been a better time for employers to reevaluate their current plan design and, if necessary, add or update features that align with their business objectives and retirement plan goals.


Cycle 3 Deadline is Next Year


Every six years, the IRS requires business owners to restate their pre-approved qualified retirement plan documents to ensure they are up-to-date and compliant with current regulatory and/or legislative changes. A restatement means the plan document must be completely rewritten to reflect mandatory regulatory changes, as well as any voluntary changes made to the plan since the last update. But don’t worry, this is very normal and nothing to fear.


The latest restatement cycle for these plans began on August 1, 2020 and will close on July 31, 2022. It’s known as “Cycle 3,” since it’s the third restatement period required under the pre-approved retirement plan program.


Since the last restatement period that ended in April 2016, there have been several legislative and regulatory changes that impact retirement plans. However, this restatement period doesn’t include regulations introduced in the Setting Every Community Up for Retirement Enhancement (SECURE) Act and the Coronavirus Aid, Relief, and Economic Security (CARES) Act. They must be addressed in separate, good faith amendments.

Restatement is mandatory. Plans that haven’t complied by the deadline could face penalties from the IRS. Even newly established or terminating plans need to restate their plan documents.


The restatement period provides employers with an opportunity to enhance their existing retirement plans — especially in light of the pandemic. Updating the plan’s design now could better position business owners, employees and companies for the future.

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