News & Analysis as of

Voluntary Fiduciary Compliance Program (VFCP)

Pillsbury Winthrop Shaw Pittman LLP

Don’t Let Bank Uncertainty Delay Payroll: Considerations for Employers

With bank uncertainty making headlines, we answer employers’ most frequently asked questions about the consequences of payroll delays, strategies for mitigating risk and more. ...more

Cozen O'Connor

Department of Labor Proposes New Self-Correction Option for Retirement Plan Prohibited Transactions

Cozen O'Connor on

The U.S. Department of Labor (the DOL) has proposed an update to its voluntary fiduciary corrections program that, although very limited, will make it easier for fiduciaries to correct some compliance errors in retirement...more

Proskauer - Employee Benefits & Executive...

DOL Proposes Self-Correction Option and Other Changes to Voluntary Fiduciary Correction Program

The U.S. Department of Labor (the “DOL”) proposed changes to its Voluntary Fiduciary Correction Program (the “VFCP”) in November for the first time since 2006. The most significant change is the addition of a self-correction...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

DOL proposes VFCP self-correction

The Department of Labor’s Employee Benefits Security Administration (EBSA) proposed updates to their Voluntary Fiduciary Compliance Program (VFCP), which would allow a self-correction component. The EBSA proposal includes a...more

Fisher Phillips

Department of Labor Proposes Self-Correction Option Under Voluntary Fiduciary Correction Program

Fisher Phillips on

The Department of Labor recently proposed updates to its Voluntary Fiduciary Correction Program (VFCP), which would allow fiduciaries the opportunity to self-correct certain matters including late deposits to a 401(k) plan....more

Groom Law Group, Chartered

DOL Suggests Changes to Its Voluntary Fiduciary Correction Program and Related Exemption

November 18, 2022, the Department of Labor (“DOL”) released a number of changes to its Voluntary Fiduciary Correction Program (“VFCP”) in both an update of VFCP and related guidance....more

Houston Harbaugh, P.C.

Late Deposits of 401(k) Contributions: New DOL Procedures to Allow for “Self-Correction”

Houston Harbaugh, P.C. on

Under federal law, amounts withheld from employee paychecks as 401(k) plan contributions are required to be promptly deposited into the trust under the plan. Failure to do so requires correction by the employer and can also...more

Miller Canfield

Proposed Changes to DOL Program Would Allow Plan Fiduciaries to Self-Correct Certain Errors

Miller Canfield on

​​​​​​​A proposed rule released last week would amend the U.S. Department of Labor's Voluntary Fiduciary Correction Program ("VFCP") to allow for self-correction by plan fiduciaries in certain circumstances. The VFCP allows...more

Foley & Lardner LLP

401(k) Compliance Check #2: Avoid Trouble By Depositing Employee Contributions on Time!

Foley & Lardner LLP on

In last month’s 401(k) Compliance Check, we discussed the importance of ensuring your 401(k) plan’s designated decision-makers are actually authorized to make plan decisions. In this month’s Compliance Check, we look at...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Those answers on that 5500, you may hear from the government

The purpose of an audit of Form 5500 is to make sure that plan sponsors voluntarily comply with the Internal Revenue Code and ERISA. Sometimes, an Internal Revenue Service (IRS) or Department of Labor (DOL) audit is done...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Correct the late deferral issue correctly

Correcting your late deferrals by depositing them and making a contribution to make up for lost earnings in your 401(k) plan isn’t enough....more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The self-correcting problem of late deferrals

When the 5500s are due and audits have to be completed, there is always an issue regarding late deferrals when the employer failed to remit these contributions as soon as possible....more

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