What Is the Post PPA Document Restatement?

Retirement plan documents include some legal documents that compose the provisions of the plan as well as the regulatory requirements for a certain plan. Most of these qualified plans utilize a plan document called preapproved. Are there some questions that keep running through your mind about these documents? Is the post PPA document restatement finished? What should I know about the post PPA document restatement?

What Is Restatement?

Preapproved plan documents are always required to be rewritten; the IRS approves them, and the plan sponsors adopt the plan every six months. This whole process is called restatement, and it gives a chance for the document language to be regularly updated for any changes in the legislative and amendments that happened when the last document was written.

The IRS has different cycles for forming contribution plans, forming benefit plans, and 403(b) plans. The formed benefit restatement window on July 31, 2020, was closed and the restatement window for formed contribution plans started on its heels.

In August 2022, the formed contribution window was opened. The restatement is mostly known as the post-PPA restatement or Cycle 3 restatement. But is the post-PPA document restatement finished?

What Changed in Cycle 3?

Some terminologies and the naming convention that were previously used to identify different types of plans are one of the things that changed in Cycle 3. In previous years, terms such as "prototype," "volume" and "master" were commonly used to describe various plan types.

Those words in Cycle 3 have been eliminated. The new restatement replaced all those words with just one simple term (pre-approved plan). Under the newly formed convention, there are only two types of pre-approved plans available: non-standardized and standardized. What should I know about the PPA document statement?

Non-Standardized Pre-Approved Plan

The provision within this type of plan doesn’t simply have to be a safe harbor. This offers greater flexibility for certain employers during the designing process of this kind of plan.

Standardized, Pre-Approved Plan

This type of plan is limited in many different ways because of the provision of being a necessity to have a safe harbor. These limitations affect what changes the client or employer may introduce during the designing process of the plan.

What Kinds of Retirement Plans Are Included?

The formed contributions plan restatement has all the preapproved plan documents for money purchase, 410(k) and profit-sharing plans. In addition, church 401(k) and ESOP plans can use some of the preapproved plans for the first time with the restatement. Some of the plans that use a design plan individually may also be able to start using the pre-approved plan in this cycle.


Is the post-PPA document restatement finished? What should I know about the post-PPA document restatement? You know you have answers to these two questions and broad knowledge of restatement. It is easy to decide the type of restatement plan that you fit into. If you are in doubt, at Fiduciary Advisors, LTD, we can help you with planning and designing employee retirement programs. Visit us today at 4242 N 19th Ave Suite 150, Phoenix, AZ 85015, or call us toll-free at (800) 591-2211, or contact David Ludwig at (602) 864-1012.