News & Analysis as of

Self-Correction Programs Internal Revenue Code (IRC)

Proskauer - Employee Benefits & Executive...

New “Self-Correction” Option for Voluntary Fiduciary Correction Starts March 17, 2025

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

Groom Law Group, Chartered

DOL Finalizes Update to Voluntary Fiduciary Correction Program

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

Seyfarth Shaw LLP

DOL Issues New Guidance Streamlining the Voluntary Fiduciary Correction Program

Seyfarth Shaw LLP on

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

Husch Blackwell LLP

New Simplified DOL Rules for Self-Correcting Delinquent Contributions

Husch Blackwell LLP on

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

Dickinson Wright

If the Deadline for Self-Correcting Retirement Plan Errors Is Indefinite, Why Do I Have to Hurry?

Dickinson Wright on

Section 305 of SECURE 2.0 added rules for self-correcting a new category of retirement plan errors under the Employee Plans Compliance Resolution System (“ECPRS”). Specifically, Section 305 allows an “eligible inadvertent...more

Foley & Lardner LLP

Diving Into SECURE 2.0: New DOL Lost and Found, Updates to EPCRS, and Delayed Implementation of Roth Catch-up Requirement

Foley & Lardner LLP on

The SECURE 2.0 Act of 2022 (SECURE 2.0) significantly changes the legal and administrative compliance landscape for U.S. retirement plans. Foley & Lardner LLP is authoring a series of articles that take a “deep dive” into key...more

Bricker Graydon LLP

Why Time is of the Essence More than Ever in Correcting Retirement Plan Errors

Bricker Graydon LLP on

Errors in retirement plans happen even to the most well-intentioned plan sponsors. Several decades ago, the IRS published the first version of the Employee Plans Compliance Resolution Program (EPCRS), which outlines...more

Bradley Arant Boult Cummings LLP

SECURE 2.0: Retirement Plan Changes for 2023

The SECURE 2.0 Act of 2022 was enacted at the end of last year as part of the Consolidated Appropriations Act of 2023. The act sets forth a number of changes affecting retirement plans that go into effect over several years....more

Proskauer - Employee Benefits & Executive...

SECURE 2.0 Delivers New Rules for Correcting Retirement Plan Errors

As part of our ongoing series on SECURE 2.0, this post discusses three significant changes to corrections of common retirement plan errors: (1) New rules for correcting overpayments, (2) expansion of the Self-Correction...more

Proskauer - Employee Benefits & Executive...

EPCRS Update Offers New Tools to Correct Retirement Plan Errors

The IRS recently updated its “Employee Plans Compliance Resolution System” (EPCRS).  By way of background, EPCRS is a correction program administered by the IRS for plan sponsors to correct certain retirement plan errors. ...more

Faegre Drinker Biddle & Reath LLP

Revised IRS Correction Procedures (EPCRS) Include Helpful Changes

On July 16, 2021, the Internal Revenue Service (“IRS”) published an updated version of its correction procedures for qualified retirement plans, Revenue Procedure 2021-30, the Employee Plans Compliance Resolution System...more

McDermott Will & Emery

Need a Do-Over? IRS Expands and Updates Qualified Plans Correction Guidance

McDermott Will & Emery on

The Internal Revenue Service (IRS) issued Revenue Procedure 2021-30, which provides an updated version of the Employee Plans Compliance Resolution System (EPCRS). EPCRS is the IRS’s comprehensive program for plan sponsors to...more

Foley & Lardner LLP

Some Welcome News: IRS Expands and Modifies Its Correction Methodology with New Employee Plans Compliance Resolution System...

Foley & Lardner LLP on

Plan sponsors and other administrators of eligible retirement plans must ensure that these plans are operated properly in accordance with the applicable requirements of the Internal Revenue Code, including the applicable plan...more

Morgan Lewis

IRS Expands Self-Correction Procedures, but Eliminates Anonymous Voluntary Correction Program

Morgan Lewis on

The Internal Revenue Service (IRS) made important changes to the Employee Plans Compliance Resolution System (EPCRS) in Revenue Procedure 2021-30 that are helpful for plan sponsors as they expand the ability of plan sponsors...more

Buchalter

IRS Expands Self-Correction under EPCRS and Adds New Overpayment Correction Methods

Buchalter on

On Friday, the IRS issued Revenue Procedure 2021-30 expanding the Employee Plans Compliance Resolution System (“EPCRS”)—a voluntary program for correcting errors in tax-qualified and section 403(b) plans—by adding two new...more

Fisher Phillips

Employers Now Have New Opportunities For Self-Correction Under EPCRS

Fisher Phillips on

The Internal Revenue Service recently amended its Employee Plans Compliance Resolution System (EPCRS) to allow more retirement plan qualification failures to be self-corrected, including retroactive plan amendments. This is...more

McDermott Will & Emery

IRS Expands Self-Correction Program, Provides Welcome Relief for Plan Sponsors

McDermott Will & Emery on

The IRS recently released an updated version of EPCRS, the IRS’s program for correcting errors that occur under tax-qualified retirement plans. The latest version of EPCRS makes it easier for plan sponsors to self-correct...more

Snell & Wilmer

To Err is Human – To Forgive is Up to the IRS in Rev Proc 2019-19

Snell & Wilmer on

The IRS recently issued its latest version of the Employee Plans Compliance Resolution System (“EPCRS”) in Rev. Proc. 2019-19. The EPCRS is the IRS program that assists employers in correcting both operational and document...more

Burr & Forman

Correcting Retirement Plan Errors Just Got Easier

Burr & Forman on

The Internal Revenue Service (IRS) issued Revenue Procedure 2019-19 on April 19, 2019, updating the Employee Plans Compliance Resolution System (EPCRS) to expand the types of plan errors that can be corrected under EPCRS....more

Ballard Spahr LLP

IRS Expands Determination Letter and Self-Correction Programs

Ballard Spahr LLP on

The IRS announced yesterday that it will expand its determination letter program for tax-qualified retirement plans. Under previous IRS procedures, a plan sponsor could submit its plan document to the IRS, and the IRS would...more

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