After annoying many plan sponsors and plan providers by increasing user fees for their voluntary compliance program (VCP), the Internal Revenue Service (IRS) goes the other way by increasing the number of opportunities for plan sponsors to correct errors through the self-correction program (SCP) and avoid a VCP application.
Through Revenue Procedure 2019-19, the IRS expanded the SCP and what changes can be made without the more expensive VCP option.
SCP was expanded to allow for self-correction of plan document failures, plan loan failures, allowing for retroactive plan amendments (which was never allowed without a VCP application).
So if you have a plan error that needs to be corrected, it’s possible that it will be less expensive if allowed under SCP.
