On April 19, 2019, the Internal Revenue Service (“IRS”) released Revenue Procedure 2019-19 (the “Revenue Procedure”) and a separate IRS Release (the “Release”) updating the Employee Plans Compliance Resolution System (“EPCRS”). The Revenue Procedure provides significant changes to the self-correction program under EPCRS (“SCP”) and expands the circumstances under which plan failures may be corrected under the SCP.
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