PODCAST: Williams Mullen's Benefits Companion - SECURE 2.0 Act Relief for Plan Corrections
Historically, the IRS' Employee Plans Compliance Resolution System (EPCRS) has provided employers structured options for correcting retirement plan failures. Under this framework, certain operational errors qualified for...more
The DOL recently updated the Voluntary Fiduciary Correction Program (VFCP). The VFCP encourages employers to voluntarily correct certain violations of ERISA to avoid DOL civil enforcement penalties....more
Starting March 17, 2025, the Employee Benefits Security Administration’s Voluntary Fiduciary Correction Program (“VFCP”) will have a “self-correction” option. Although the new option eliminates the need to wait for formal...more
The Department of Labor announced that its Employee Benefits Security Administration has updated its Voluntary Fiduciary Compliance Program, allowing employers more efficient ways to voluntarily correct compliance issues in...more
The Voluntary Fiduciary Correction Program (VFCP) has long been a source of reprieve to plan sponsors and fiduciaries from enforcement actions by the Department of Labor (DOL), by allowing the voluntary correction of a number...more
As announced in our previous HR Law Talk blog post, on January 15, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) published a much anticipated amended and restated version of the...more
On January 15, 2025, the Department of Labor (“DOL”) issued notice amending its Voluntary Fiduciary Correction Program (“VFCP”), along with related final amendments to Prohibited Transaction Exemption 2002-51 (“PTE 2002-51”),...more
On January 14, 2025, the Employee Benefits Security Administration (EBSA) within the Department of Labor (DOL) updated its Voluntary Fiduciary Compliance Program (VFCP). The VFCP allows plan officials to correct certain...more
The Department of Labor (DOL) has issued a much awaited amendment to its Voluntary Fiduciary Correction Program (VFC Program). Notably, the amendment adds a self-correction feature for the delinquent transmittal of...more
The DOL updated its voluntary fiduciary correction program (“VFCP”) which was introduced over 20 years ago to allow plan sponsors to corrected enumerated fiduciary breaches. The amended VFCP now allows for self-correction of...more
The January Monthly Minute highlights a recent Texas court decision holding ESG investing violated ERISA and a new development in the J&J prescription drug case that found plaintiff lacked standing to sue, and also digs into...more
On January 14, 2025, the U.S. Department of Labor’s Employee Benefits Security Administration (EBSA) announced significant updates to the VFCP. These changes, effective March 17, 2025, introduce a self-correction feature for...more
On January 14, 2025, the US Department of Labor (“DOL”) released a final regulation revising its Voluntary Fiduciary Correction (“VFC”) Program and related prohibited transaction exemption (“PTE”) 2002-51 to add a...more
On January 14, 2025, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) released its long-awaited final rules regarding changes to the Voluntary Fiduciary Compliance Program (VFCP). The new...more
Now that 2022 is behind us, the final steps in compliance with PTE 2020-02 must be satisfied. Those steps are (i) conducting the annual retrospective review and the resulting report (within six months) and (ii) correcting any...more
On November 21, 2022, the US Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) released a proposed amendment and restatement of the Voluntary Fiduciary Correction Program (VFCP), along with a...more
The November Monthly Minute examines the new DOL final rule addressing fiduciary duties relating to ESG investing and shareholder rights, and a DOL proposed rule that would permit self-correction of late employee...more
We all know that when we make a mistake, it’s best that we correct them. Yet too many plan sponsors take a gamble by not self-correcting errors made in their plan...more