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Cycle 3 DC Plan Restatement Resources


Every 6 years or so, the IRS requires the vast majority of company-sponsored retirement plans to update their plan documents through a process called "restating" the document. For 401(k) and other defined contribution plans, this process started for the third time in summer 2020. We've created this resource page to answer your questions about the restatement process.

TL;DR? We have a shorter overview for you here. 


Plan Restatements

A plan restatement is a complete re-write of your plan document that incorporates changes from any mandatory or voluntary amendments that have been adopted since the last time the document was restated. 

Mandatory Restatements |All qualified retirement plan documents are required to be updated to reflect legislative and regulatory changes from time to time.  Defined contributions plans (such as 401(k) and profit sharing plans) that use a document that is pre-approved by the IRS must go through this restatement process on this six-year schedule.


For more information on mandatory and amendments and restatements, along with a list of the various requirements - going back more than 15 years beginning with the most recent Cycle 3 Restatement and working backward - click here.

For information regarding voluntary updates to your plan document, i.e. amendments or restatements other than those required due to law changes, click here.


Plan Re-Design Options

A mandatory plan restatement is a perfect time to consider any updates you might want to make to your plan’s design.  After all, if you are already re-writing your plan document anyway, why not incorporate any changes you have been considering.  It is a regular part of DWC’s process to review plan designs and suggest options that can make a plan more cost-effective, efficient, or both.  And we are also available to discuss any ideas or questions you might have.
DWC has a full library of plan design resources to answer many common questions. We've also highlighted a few other design ideas for your consideration below. Not sure where to start? Not to worry, you can always contact your friendly neighborhood DWC consultant and we can help you determine which options are best for your organization.
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  • After-Tax Contributions Contributing to your retirement plan after-tax provides additional benefits. Learn more in this article series.
  • Automatic Enrollment This feature has gained quite a bit of popularity over the years.  Here are the basics.
  • Eligibility All of the moving parts can make determining when a new hire is eligible for your 401(k) plan a little complicated. We've outlined a way for you to simplify it here.
  • Hours of Service You've determined how you want to set up eligibility for your 401(k) plan, but counting hours of service sounds like a nightmare. Here's how you can make it easier.
  • Profit Sharing  Many retirement plans are design to include a feature that allows the plan sponsor to make a profit sharing contribution each year. Get the details here.
  • Profit Sharing - New Comparability  Want to maintain the same profit sharing contributions you've been making for years, but also give yourself the option to give different amounts to different employees in the future? Here's what you need to do.
  • Safe Harbor A safe harbor feature can benefit your participants, allow you to contribute more, and provide a free pass on some of the annual compliance requirements. This resource page can get you started.

Cycle 3 Restatement FAQs

We’ve addressed a full list of common questions about the who, what, why, and how of Cycle 3 restatements in our FAQ here.  As we cover additional related questions in our Questions of the Week, we will include them here for a one-stop-Cycle 3-resource shop.  Have a question we haven’t answered yet?  Submit it here.

  • Discretionary Contributions As part of the Cycle 3 Restatements, the IRS is placing some additional limitations on just how much discretion is allowed when determining company matching contributions. Get the details here.
  • Plan Terminations If you're planning on terminating your plan in the near future, do you still need to do the restatement? Find out here.
Download your free copy of our Sample Plan Design Projection Report