Cycle 3 Restatement FAQS

The Cycle 3 Plan Document Restatement process is for all Cash Balance and Defined Benefit Plans. An IRS-required restatement of plan documents happens approximately every six years, and our team will be working hard over the next few months to accomplish this for all our clients.

A restatement is a re-writing of the adoption agreement. It incorporates changes from any plan amendments that may have been adopted since the last time the document was re-written. Retirement plans must be restated from time to time; however, they are divided into various cycles depending on plan type and document type.

Documents are written based on laws and regulations set by Congress, the IRS and the DOL. As those laws and regulations change, documents must be updated to mirror those changes.  Failure to do so can result in plan disqualification and could subject your company to substantial tax sanctions.

This is a Government mandated restatement, it is not optional.

This is an option that we have considered in the past, but the current structure makes more sense for a variety of reasons. We never know exactly when the restatement cycle will begin, so charging a monthly fee may not be fair. Some clients may leave in the middle of a cycle and therefore not need the restatement when it comes due, this would mean they paid for something that they never received. The most logical solution is to charge this fee at the time of restatement.

We do this to ensure that our clients are committed to having PDC handle the restatement. This is a very common TPA practice. Receiving payment before makes sure that all the efforts that go into the restatement won’t be wasted time that takes away from other important client services.

It can vary based on the type of vendor, but the great majority of Third Party Administration firms charge for this service.  Bundled Recordkeeping vendors may not charge in some situations but this is because they generate large revenue from asset based fees.  When determining what PDC would charge for this service, we looked at all of our peers and the average fee represented. Our fee is definitely competitive and within industry norms.

Your Client Account Manager has in-depth knowledge of this restatement process and can answer any questions that you may have.   

The restatement deadline is March 31, 2025.

Although we cannot negotiate or lower this fee, we are very willing to work with our valued clients and offer flexible options in terms of payment structure. Please contact our Accounts Receivable Department at accounting@plandesign.com or 650-425-7925 to discuss options.

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